health products regulatory authority annual report 2017 · 9 applications for new clinical...
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Health Products Regulatory Authority
Annual Report 2017
HPRA Annual Report 2017
1
Contents
2017 STATISTICS AT A GLANCE 2
CHAIRPERSON’S STATEMENT 3
AUTHORITY MEMBERS 5
MANAGEMENT COMMITTEE 6
CHIEF EXECUTIVE’S REPORT 7
HUMAN MEDICINES 11
MEDICAL DEVICES 22
BLOOD, TISSUES AND ORGANS 28
VETERINARY MEDICINES 30
SCIENTIFIC ANIMAL PROTECTION 34
CONTROLLED DRUGS AND PRECURSOR CHEMICALS 36
COSMETIC PRODUCTS 37
OTHER REGULATORY PROGRAMMES 38
OUTREACH AND ENGAGEMENT 40
ORGANISATIONAL DEVELOPMENT 43
AUTHORITY AND COMMITTEES 45
APPENDICES 47
FINANCIAL STATEMENTS (SEE SEPARATE PDF DOCUMENT)
HPRA Annual Report 2017
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2017 Statistics at a Glance
20 - THE NUMBER OF PATIENTS WHO COMPLETED THE HPRA MODULE OF THE IPPOSI PATIENT
EDUCATION PROGRAMME
---------------
4.5 - OUR ASSESSMENT RATING OUT OF 5 UNDER BEMA, THE BENCHMARKING PROGRAMME FOR
EUROPEAN MEDICINES AGENCIES
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684 - THE TOTAL NUMBER OF NEW HUMAN MEDICINES AUTHORISED
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96 APPLICATIONS ISSUED FOR CLINICAL TRIALS OF HUMAN MEDICINES
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152 NEW MARKETING AUTHORISATION APPLICATIONS ISSUED FOR VETERINARY MEDICINES
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9 APPLICATIONS FOR NEW CLINICAL INVESTIGATIONS OF MEDICAL DEVICES
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131 MANUFACTURING LICENCES IN PLACE AT YEAR END – 111 FOR HUMAN MEDICINES AND 20
FOR VETERINARY MEDICINES
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3,857 EXPORT CERTIFICATES ISSUED – 1,486 CERTIFICATES FOR MEDICINES AND 2,371 FREE SALE
CERTIFICATES FOR MEDICAL DEVICES
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29 EU PSUR SINGLE ASSESSMENT PROCEDURES FOR HUMAN MEDICINES LED BY THE HPRA
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4,402 SUSPECTED ADVERSE REACTION REPORTS FOR HUMAN MEDICINES RECEIVED
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397 REPORTS OF SUSPECTED ADVERSE REACTIONS ASSOCIATED WITH USE OF VETERINARY
MEDICINES
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2,339 MEDICAL DEVICE VIGILANCE REPORTS RECEIVED AND ASSESSED
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1,281 MARKET SURVEILLANCE CASES UNDERTAKEN IN RESPECT OF MEDICAL DEVICES
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89 MEDICINE RECALLS CONSISTING OF 82 HUMAN MEDICINES AND 7 VETERINARY MEDICINES
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118 GMP INSPECTIONS CONDUCTED AT MANUFACTURING SITES FOR HUMAN AND VETERINARY
MEDICINES, AND ACTIVE SUBSTANCES
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3 REGULATORY INFORMATION SEMINARS HOSTED – IN LEITRIM, LIMERICK AND DUBLIN – FOR OUR
COSMETIC STAKEHOLDERS
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200,000 UNITS OF ILLEGAL PRESCRIPTION MEDICINES DETAINED IN IRELAND DURING PANGEA X
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HPRA Annual Report 2017
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Chairperson’s Statement
It is a great pleasure to introduce the 2017 annual report, which outlines the extensive work of the
HPRA over the past 12 months.
As Chair of the HPRA, I see my role as being to work with the members of the Authority to support the
Chief Executive and the members of the executive team in our mission to continually protect and
enhance public and animal health. As outlined in my report last year, we are guided by our strategic
plan and we depend ultimately on having dedicated, qualified and experienced staff to deliver on our
ambitions. This is how we ensure that the highest standards of excellence and capabilities are
maintained and continually evolve so as to meet all our stakeholders’ needs into the future.
In order to measure our effectiveness as an organisation, we engage in external benchmarking
programmes with our counterparts across Europe. The learnings from such reflective and thorough
analysis continue to drive the HPRA’s ambition to deliver better outcomes for patients and members
of the public.
In this respect, I would like to highlight two significant developments in 2017; our involvement in the
Joint Audit Programme (JAP) for inspections and our participation in the Benchmarking of European
Medicines Agencies (BEMA).
The European Heads of Medicines Agencies (HMA) Joint Audit Programme is an external
benchmarking process. The HPRA’s quality system for good manufacturing practice (GMP) –
incorporating inspection and licensing of manufacturers of medicines, management of quality defects
and recalls, and sampling and analysis of medicines – was evaluated under this programme in May.
The audit was observed by the US FDA as part of its review of equivalency of our systems in relation to
the US/EU mutual recognition agreement (MRA) on GMP inspections. The audit was successful,
validating the strength of the HPRA’s processes and procedures for inspection and quality defect
management. As a result, I look forward to the significant achievement of Ireland’s anticipated
inclusion as a country recognised under the MRA during 2018.
This was followed in October by the HPRA’s participation in BEMA, the benchmarking programme for
European human and veterinary agencies which is now in its fourth cycle. This programme aims to
contribute to the development of a world-class pharmaceutical regulatory system across Europe,
based on a network of agencies consistently employing recognised best practices. The HPRA’s
assessment, which was carried out by representatives from three other EU regulatory agencies,
resulted in an excellent overall rating of 4.5 (out of 5). Of particular note, there was a top rating of 5
for nine specific indicators.
One of those indicators related to human resources and I am very proud of the emphasis that the
Authority places on the development of its most important asset, its staff. In 2017, we saw the second
year of activity under the organisation’s HR Strategy and the commencement of the HPRA’s
Management Development Programme focusing on developing leadership capabilities and talent
management. This investment in our people managers is central to developing the internal capabilities
across the organisation for now and into the future. Investment in technical expertise was also a key
priority in 2017.
As an organisation, the HPRA always strives to develop new approaches to foster engagement and
ensure we best serve public and animal health. For many reasons 2017 was a notable year in this
regard. For example, as outlined by our Chief Executive in her 2017 Report, the management of Brexit
and its potential implications in terms of medicines availability, has brought about the need for a
different approach to our engagement with patients and healthcare professionals for the purposes of
ensuring effective management of this situation.
HPRA Annual Report 2017
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The Authority also recognises the importance of transparent and open communication with our
stakeholders, especially patients, healthcare professionals and members of the public. During 2017, a
number of new initiatives were progressed to enhance and develop our communications. I look
forward to working further with the Authority and HPRA staff in shaping and evolving the work that
has commenced and I intend to report more fully on this in next year’s annual report.
Forward Focus
Looking ahead, the members of the Authority and I are ever conscious that the HPRA faces a range of
opportunities and challenges in 2018. These include management of a changing complex regulatory
environment in Europe across many areas including medical devices, clinical trials and veterinary
medicines, supporting innovation and, of course, Brexit. All of these activities will be addressed and
prepared for alongside the critical routine work of the organisation and its ongoing development of
capabilities and support services. We are greatly assured by the expertise, preparedness and
pragmatic approach of the agency staff in addressing its many priorities.
Over the coming years, working together, we will ensure that the HPRA remains alert and agile with
the capability and capacity to anticipate and meet the demands of a rapidly changing external
environment. As always, we remain fully committed to our constant and common goal of protecting
the health and safety of all those who use health products.
Acknowledgments
On behalf of the Authority, I thank the Minister for Health, the Minister for Agriculture, Food and the
Marine, their advisors and the staff of their departments for their ongoing support of the HPRA and its
activities.
I would particularly like to thank the Chief Executive, management and all the staff and to
acknowledge the excellence of their work. The very significant progress and results achieved in 2017
are clearly reflected throughout this report.
On a personal note, as Chairperson, I would like to express my gratitude to the members of the
Authority for their expert input and support throughout 2017. Finally, my thanks also to the Chairs and
members of the HPRA advisory committees and sub-committees. The contribution of all the
independent experts who give freely of their expert opinion and time is of huge value to our
organisation.
Ann Horan
Chairperson
HPRA Annual Report 2017
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Authority Members
The Authority of the HPRA is appointed by the Minister for Health in accordance with the powers
conferred by subsection 2 of section 7 of the Irish Medicines Board Act, 1995. There were nine
Authority members up to 31 December 2017.
Ms. Ann Horan
Chairperson
Mr. Pat Brangan
Mr. Wilfred J. Higgins
Mr. David Holohan
Professor Mary Horgan
Mr. Brian Jones
Professor Elizabeth Keane
Professor Caitriona O’Driscoll
Dr. Diarmuid Quinlan
HPRA Annual Report 2017
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Management Committee
Dr. Lorraine Nolan
Chief Executive
Ms. Rita Purcell
Deputy
Chief Executive
Dr. J.G. Beechinor
Director of
Veterinary Sciences
Dr. Jayne Crowe
Director of Human Products
Authorisation and Registration
Dr. Caitríona Fisher
Director of Quality, Scientific
Affairs and Communications
Dr. Joan Gilvarry
Director of Human
Products Monitoring
Mr. Kevin Horan
Director of ICT and
Business Services
Mr. John Lynch
Director of
Compliance
Ms. Lynsey Perdisatt
Director of Human
Resources and Change
HPRA Annual Report 2017
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Chief Executive’s Report
In preparing my third foreword to the Annual Report since I was appointed as Chief Executive in
January 2016, I have been struck by how it has been a very busy year that has seen many new
opportunities and developments emerge. It continues to be my privilege to lead a dynamic Agency
that makes a major and tangible contribution every day to safeguarding public and animal health in
Ireland and beyond.
2017 resulted in some clear step changes for the Health Products Regulatory Authority (HPRA) and
the continued progression of our organisation in line with the goals set by our 2020 Strategic Plan.
During the year, we made significant inroads in advancing our processes for direct engagement with
patients and the public, healthcare professionals and innovators. I believe that this progress brought
about in 2017, which is further expanded below, is changing the way in which we are connecting with
our key stakeholders and is delivering more meaningful two way engagement. In addition to
positioning the HPRA as being accessible and approachable in terms of our remit of protection of
public and animal health, developments in 2017 have ensured that the value-add of our regulatory
approach continues to be better understood by our stakeholders. It has also played a significant role
in informing us on how we should continue to grow and develop our organisation into the future.
Stakeholder Engagement and Communications
One of the developments from 2017, which I am particularly proud of, was the execution of our role as
an education partner in the Irish Platform for Patient Organisations, Science and Industry (IPPOSI)
Patient Education Programme. The HPRA’s contribution focused on the areas of regulatory affairs,
medicinal product safety and pharmacovigilance. This initial programme, tailored for Irish patient
communities, concluded with the graduation of 20 expert patients who will play an important role in
sharing their knowledge and experiences for the benefit of others.
The HPRA, through our colleague Almath Spooner, the Vice-Chair of the Pharmacovigilance Risk
Assessment Committee (PRAC), was centrally involved in the first ever public hearing at the European
Medicines Agency (EMA) held in September. This unique opportunity to give EU citizens a voice in the
evaluation of the safety of medicines and empower them to express their views on issues related to
the management of risks, is something to emulate at national level. In 2017, our mechanisms for
engagement with patient groups and healthcare professionals have been further enhanced to involve
greater use of multi-stakeholder discussion forums for key medicines safety issues. This is something
we believe will better serve the public as it will deliver greater alignment between health product
regulation and healthcare provision.
As an organisation, the HPRA is completely committed to ensuring that the market for health
products in Ireland is highly and appropriately regulated to enable the highest standards of public and
animal health protection. Consistent with this, we continue to apply our expertise to ongoing safety
assessment and monitoring of authorised medicines on the market whilst utilising our regulatory
powers as required. Simultaneously, we place considerable focus on minimising the entry of illegal
medicines to the marketplace. In this regard, Operation Pangea again highlighted the significant
collaboration taking place between the health product regulators, law enforcement agencies and the
private sector in combating the illegal supply of medicines and medical devices on an annual basis.
The 2017 operation, which represented the tenth year of Pangea, took place in September 2017, and
was led by the HPRA in partnership with Revenue’s Customs Service and An Garda Síochána. It
resulted in the detention of over 200,000 units of illegal prescription medicines, a threefold annual
increase. This outcome was a result of enhanced intelligence-led enforcement activities building
successfully on our strong year-round collaboration with our partner agencies. Globally, Pangea led to
HPRA Annual Report 2017
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over 25 million illegal medicines and medical devices worth over US$56 million being detained across
123 countries. Significantly, from a public health perspective, this enforcement operation also
provided the HPRA and our partner organisations with a key opportunity to highlight the serious risks
involved in sourcing illegal prescription medicines and medical devices online, many of which are from
dubious sources and may be counterfeit.
Supporting Innovation
In 2017, we also continued to identify ways to support and facilitate product development for patients
in need of new treatments by further improving early engagement with key stakeholders. The
Innovation Office at the HPRA was established in late 2016 with our first innovation stakeholder event
to provide a platform for sharing knowledge and information taking place in May 2017. The
conference brought together researchers, entrepreneurs and other interested parties from various
sectors including academia, research organisations, SMEs and the life sciences industries. Enhancing
communication and strengthening the links between academia, industry and regulators is a critical
support for a sector which is highly dynamic and innovative. This area was a key focus for us during
the year as we continued to build on our programme of outreach with the sector which first
commenced in 2016.
Our focus on innovation also extended to involve greater contribution at European level, through the
Innovation Network, and internationally. Specifically, we assumed a role in supporting innovation
through our participation in the International Coalition of Medicines Regulatory Authorities (ICMRA)
which established a new strategic priority in innovation during the year. This priority includes a work
stream, focusing on outcomes of horizon scanning, which is jointly led by the HPRA and the EMA.
BREXIT
Many of the advancements we made in 2017 were brought about as part of our proactive approach to
managing the significant challenges presented by the United Kingdom’s decision in 2016 to withdraw
from the EU. Our focus since this announcement has always been, and will continue to be, public
health protection. The HPRA hosted a Brexit stakeholder event in August 2017, the first such event
hosted by a competent authority in Europe. Brexit has potentially significant implications for the
European regulatory network as a whole and particularly for Ireland given our shared marketplace
with the UK. We have confirmed our commitment to support the European network to ensure that the
resources and capacity required are available to guarantee an orderly redistribution of the work
currently undertaken by the UK and we will continue to position our agency to swiftly contribute to
addressing any additional issues that may arise from the UK’s exit. Through this preparedness, and our
support of the EMA’s relocation to Amsterdam, we will assist the smooth continuation of EMA
activities and help to deliver the network’s shared goal of protecting human and animal health in
Europe at all times. Nationally, the HPRA is fully committed to working to ensure that the availability
of medicines and other health products is not negatively impacted by Brexit and we have been
proactively focused on supporting measures to ensure sustainable levels of product marketing
authorisations in Ireland.
One of the consequences of Brexit is that the EMA has to relocate from its present location in London.
During 2017, the HPRA, working with colleagues from the Department of Health and IDA Ireland, as
well as other Government officials and diplomats in Brussels and throughout Europe, led the
development of a proposal to have the Agency relocated to Dublin. Ireland was one of nineteen
countries that submitted proposals to the European Commission. The decision was subsequently
made through the European Council in September and Amsterdam was chosen as the new location
for the Agency. The HPRA looks forward to supporting both the EMA and the European network in
ensuring a successful transition to the new location in the Netherlands which will begin during 2018.
HPRA Annual Report 2017
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Although Dublin was not the chosen location, the preparation of the proposal, the strength of which
was recognised by numerous stakeholders, was a unique opportunity to showcase the many strengths
of Ireland in relation to the wider life sciences sector, our access to scientific talent and the strong
regulatory environment that has been established by the HPRA. It was a great pleasure to work with
our Government colleagues on this project, which was of significant strategic importance from the
perspective of public health and promoting Ireland’s economic interests and reputation
internationally.
Separate to Brexit, but nonetheless related, the HPRA established a new project on medicines
shortages in 2017. This followed a request by the Department of Health for the HPRA to undertake a
role in the national coordination of medicines shortages following a review it convened under its
Medication Safety Forum. Due to a range of factors, medicine shortages are increasing in prevalence
and affecting all the global regions. The HPRA-led project is focused on developing enhanced
methods and devising new solutions to ensure better coordination among key stakeholders in Ireland
for both the prevention and management of medicines shortages. The objective is to develop a
national protocol for management of shortages to ensure better patient outcomes and enhanced
communication and engagement on this key public health issue.
Building Internal Capabilities
The environment in which we operate is fast paced, dynamic and evolving. Our strategic goals drive us
to develop our internal capabilities and plan for future expertise requirements in line with the constant
development of new and innovative health products and technologies. In the past year, our focus has
been on attracting new talent with diverse and expert skills in the areas of software, analytics and new
areas of clinical interest. In addition, we have continued to invest in the development of the skills and
expertise of our staff. 2017 saw further developments under our HR strategy, which sets out a five-
year roadmap for talent development within the HPRA. Key deliverables achieved last year include the
launch of our Management Development Programme.
All the while, our regulatory environment continues to evolve. Indeed, during 2017, political
agreement was reached on the new medical devices regulatory framework for Europe. This is a
significant development in further strengthening the regulatory environment within which we operate
to provide further protection for patients and users of medical devices. It also requires the HPRA to
continue to evolve and develop our approach so that as an organisation we can continue to deliver a
robust system of regulation for medical devices which meets current and future needs. A key focus for
the year ahead will be reshaping our internal structures and processes for medical devices to allow us
to effectively deliver our remit in the context of the revised framework and, most importantly, to best
serve the needs of Irish patients.
Network Participation
Throughout the year, the agency has worked very closely with our European counterparts through
representation on a wide range of committees and working groups at the EMA and within the Heads
of Medicines Agencies’ network, as well as at a bilateral level. HPRA representatives continue to hold
the substantial roles of Chair of the EMA’s Committee for Medicinal Products for Veterinary Use
(CVMP) and Vice-Chair of the EMA’s Pharmacovigilance Risk Assessment Committee (PRAC).
We have also continued to grow our participation and footprint within international networks through
our work in the International Coalition of Medicines Regulatory Authorities and the International
Medical Device Regulators Forum. The work of both these groups aims to enhance global
harmonisation among regulators. As an agency, we are honoured to be the host and are very much
looking forward to the World Health Organisation’s International Conference of Drug Regulatory
HPRA Annual Report 2017
10
Authorities (ICDRA) in Dublin in 2018 and work continued during the past year in preparation for this
major event.
A Look Forward
The HPRA regulates a wide range of health products in Ireland. Indeed, as a regulator of ten classes of
health products across nine regulatory regimes, we have one of the widest remits when compared to
other agencies internationally. We set ourselves high standards and are well placed to continue on our
planned development trajectory. To achieve our potential, we must reflect on our achievements in
2017 and plan for the known and indeed the unknown opportunities and challenges that lie ahead.
Our investment in building internal capabilities, stakeholder engagement and innovation supports,
position us well as we continue on our journey to meet the challenges of being a regulator of the
future.
Acknowledgments
I would like to thank and acknowledge the support and co-operation of the Ministers and staff of the
Department of Health and the Department of Agriculture, Food and the Marine during 2017.
On behalf of our management team and all our colleagues, I also wish to thank the members of the
Authority and advisory committees for their continued contribution and commitment to the HPRA.
Their independent expertise and advice is of huge value to our agency. My particular gratitude to the
Authority Chairperson, Ann Horan, and the Authority members for their support and dedication
throughout the year.
I must expressly thank my colleagues within the HPRA for the tangible results and achievements
outlined in this annual report. It clearly reflects the expertise, commitment and professionalism
displayed across the organisation as we both delivered on our planned work programme and
responded to the opportunities and challenges that arose.
The HPRA is the agency it is because of all those who contribute to its work: the members of the
Authority, scientific committees and advisory groups, our staff, Management Board and national
experts, and all our stakeholders who share their views and experiences to help us deliver on our
absolute commitment to protect public and animal health.
Lorraine Nolan
Chief Executive
HPRA Annual Report 2017
11
Human Medicines
The HPRA grants licences for medicines subject to a review of their safety, quality and effectiveness
and continuously monitor their use once they become available on the Irish market. We also approve
and monitor clinical trials, inspect and license manufacturing sites and wholesalers, and investigate
activities associated with the illegal supply, manufacture or advertising of medicines.
AUTHORISATION AND REGISTRATION
Prior to a new medicine being placed on the Irish market, it must be assessed and authorised
(licensed) by the HPRA or by the European Medicines Agency (EMA) in conjunction with the
European Commission. The assessment involves establishing that a medicine’s health benefits
outweigh its known risks. Where this is the case, it may be granted a marketing authorisation.
There are a number of routes through which a product can be authorised by the HPRA. These
include the national procedure, the mutual recognition procedure (MRP) and the decentralised
procedure (DCP). Both MRP and DCP involve the simultaneous submission of applications in a
number of EU Member States.
The centralised route is coordinated by the EMA and results in an authorisation which is granted by
the European Commission and is valid across Europe. The assessment is carried out by Member
States appointed as lead assessor (rapporteur), joint lead assessor (co-rapporteur) and peer
reviewer, with input also from all other Member States.
During the year in review, the total number of new medicines authorised in Ireland was 684. This
compares to 637 in 2016. The 2017 figures incorporate:
- 104 new national applications which incorporates 99 parallel import applications;
- 58 applications made under the MRP and 324 applications made under DCP. The HPRA acted
as reference (lead) Member State for the assessment of 12 of the DCPs.
- 2 rapporteurships and 10 co-rapporteurships under the centralised route. A number of these
applications were for biological medicines.
- An additional 186 medicines authorised through the centralised route where the HPRA was
neither rapporteur nor co-rapporteur.
In 2016, we established a new national scientific advice procedure to assist commercial and non-
commercial entities in the development of new or existing medicines or making applications for
clinical trial authorisation or marketing authorisations. This service complements advice which we
provide on earlier stage product development through the Innovation Office as well as scientific
advice provided at an EU level through the EMA’s Scientific Advice Working group. During the year:
- We continued a pilot study in 2017 based on a number of national scientific advice meetings.
Six meetings were held as a result of which we were able to review the cumulative experience
gained over the nine months of the pilot.
- Our external guidance document for stakeholders was revised and published to our website.
- Initial discussions were held with the National Centre for Pharmacoeconomics in late 2017 in
respect of horizon scanning, early scientific advice, the EMA-EUnetHTA three-year work plan
and patient education.
Timely access to medicines is critical for patients so they can benefit from new and promising
therapies and a number of procedures are available to assist in this.
- The HPRA secured its first rapporteurship for a medicine under the EMA’s PRIME scheme
which offers early support to developers so they are better positioned to generate robust data
HPRA Annual Report 2017
12
on the medicine and enable accelerated assessment of the marketing authorisation
application.
- A total of 96 new clinical trial applications were issued in 2017; 19 of these applications were
voluntary harmonisation procedures for clinical trials with the HPRA acting as lead Member
State for five of these co-ordinated work-sharing assessments for multinational clinical trials.
Reclassification of the legal status of medicines aims to increase the number of medicines available
to patients without prescription where it is safe to do so. This year:
- One prescription-only medicine for pain relief was authorised for non-prescription, pharmacy-
only sale while another pharmacy-only medicine, indicated for nicotine replacement therapy,
was reclassified to general sale.
In June 2013, the HPRA commenced publication of a list of interchangeable medicines to facilitate
generic substitution by pharmacists and to allow for reference pricing by the Health Service
Executive (HSE). By year end, the interchangeable medicines list included 60 active substances.
A biosimilar medicine is a biological medicine that is very similar to an original biological medicine
called the reference medicine.
- During 2017, we published an online questions and answers document which was developed
in plain English and approved by the National Adult Literacy Agency (NALA) prior to
completion in November. In addition, we commenced work on a plain English video.
- Also in November, the HPRA hosted a successful information evening for healthcare
professionals to outline how biosimilar medicines are approved for use in patients.
- During the year, we delivered a series of presentations at external events to inform healthcare
professionals and patients about the use of biosimilars. Staff members also contributed to a
number of peer-reviewed papers and conference papers that focused on this topic.
- The HPRA’s biosimilars project in conjunction with Regulatory Science Ireland was successfully
completed in 2017 with all elements of the work plan accomplished. The research scientist
who commenced work on this project in January 2016 submitted her thesis entitled ‘The
Regulatory Science of Biosimilars’ to University College Cork in December 2017.
Medicine shortages have been an ongoing concern globally and in Ireland for some years. Under
our current strategic plan, we have committed to establishing a system for co-ordinating the
management of shortages. During 2017:
- We commenced a project, following Department of Health approval, to design and implement
a system for co-ordinating the management of shortages. In Q4, we conducted an intense
phase of stakeholder engagement, meeting with patient groups, healthcare professional
groups, the HSE and various industry associations to gather their experience and perspectives
about the reasons for shortages and the appropriate management of them.
- In light of potential shortages arising from the response of companies to the exit of the UK
from the EU, we also began discussions with other regulatory authorities with a view to
developing harmonised product information and joint packaging. There were bilateral
meetings/contacts throughout the year between the HPRA and the MEB (Netherlands) and
the MPA (Sweden) to discuss labelling issues and work sharing opportunities. Discussions are
also ongoing with the UK in this regard. There is a general consensus that in so far as possible
we should continue with joint labelling and maintain the close communication between both
agencies.
We continued to monitor the numbers of unauthorised products notified to us through the exempt
medicinal product scheme. One aspect of our approach to reducing the risks to patients is to
actively seek new marketing authorisation applications for high-volume products currently being
HPRA Annual Report 2017
13
imported through this scheme. One application was received by year end and is being considered.
It is anticipated that this will be assessed under an accelerated procedure.
In November 2016, the Minster for Health requested the HPRA to provide scientific advice in
respect of the potential medical use of cannabis. The HPRA convened an expert working group to
assist with its review of this matter. The HPRA report – Cannabis for Medical Use: A Scientific
Review – outlines the key findings and conclusions of the working group. Following approval by
the Authority of the HPRA on 25 January 2017, the report was presented to the Minister for Health
on 31 January and published on the HPRA website. The HPRA then commenced a series of
engagements in respect of the report findings and met with a number of patient and public
representatives. The HPRA also appeared before the Oireachtas Joint Committee on Health to
discuss the report on 7 March.
The Minister for Health endorsed the HPRA report and established the Cannabis Reference Group
during 2017 to prepare clinical guidance and develop a national Cannabis Access Programme to
enable access to cannabis for medical use. In conjunction with stakeholders, including the HPRA,
the Department of Health is developing the Cannabis Access Programme and the Statutory
Instruments to underpin the programme.
Authorisation and registration: Key figures
2015 2016 2017
Classification queries 80 49 34
Scientific advice
Lead in EMA scientific advice:
National scientific advice (commenced in 2016)
39
--
51
13
47
6
Clinical trial applications 108 108 96
Voluntary Harmonisation Procedures (multinational
clinical trials)
Lead
Participating member state
8
15
8
22
5
14
New medicines applications for marketing authorisations
National
Mutual recognition and decentralised RMS
Mutual recognition and decentralised CMS
Centralised Rapp/Co-Rapp/Peer reviewer
137
17
422
12
71
12
365
20
104
10
370
12
Traditional herbal medicinal products under the simplified
registration scheme 7 9 4
Homeopathic medicines under the simplified rules scheme 0 1 2
Variations to marketing authorisations (Type IA, IB, II) 14,461 13,837 11,600
Articles 45 and 46 - Variations to Update Product
Information 1 1 2
Renewals of marketing authorisations 322 351 248
Transfer of marketing authorisation holder 245 209 208
Parallel product authorisations 125 57 99
Manufacturers 95 103 111
Manufacturers of investigational medicinal products 52 55 52
Wholesalers 287 318 348
Registrations for active pharmaceuticals ingredients
Manufacturers
22
21
28
HPRA Annual Report 2017
14
Importers
Distributors
37
37
41
49
59
81
Brokers 1 3 9
Export certificates 1,646 1,274 1,375
Exempt medicines programme for notification of
unauthorised medicine import
1,639,312
packs
1,827,047
packs
1,961,54
1 packs
SAFETY AND QUALITY
Under the SCOPE project (Strengthening Collaboration for Operating Pharmacovigilance in Europe)
created to support pharmacovigilance in the following EU legislative requirements that came into
effect in June 2012:
- There was collaboration with stakeholders concerning the distribution of joint DHPCs, and
targeted communications to raise awareness of the availability of educational materials on the
HPRA website.
- We engaged with IPPOSI, as part of its pilot Patient Education Programme specifically tailored
for Irish patient communities, to provide medicines safety input for patient training materials.
- Additional modalities were explored for communication pharmacovigilance issues, including
social media platforms, focused safety alerts to stakeholders and video sharing websites, while
quality standards, ‘best practice’ and training materials were implemented.
In anticipation of the changed reporting rules for the EU’s Eudravigilance database of adverse
reactions:
- The HPRA’s own adverse reaction database was updated to ensure compliance with the new
reporting standard. This was fully operational in October, ahead of the move to centralised
reporting to the Eudravigilance in November, including an updated reporting process and
training of all staff.
- Updates were given to stakeholders to facilitate appropriate and timely testing of the new
standard and reporting arrangements, including through the Medicinal Products Newsletter
and website updates and alerts.
Adverse reactions reports assist the HPRA, in co-operation with pharmacovigilance professionals in
Europe and further afield, to look for new types of reactions or changing trends in reporting.
Reports submitted to the HPRA in many instances arise from concerns occurring during
observation of an unexpected and / or unwanted event, in the context of use of a medicine. They
also include known adverse reactions, such as those described in the product information. This
year:
- 4,402 adverse reactions reports were received associated with the use of human medicines.
This represents a 35% increase in overall reporting rates compared with 2016. While there was
already a legal obligation for marketing authorisation holders (MAHs) to report all serious
adverse reaction reports of which they become aware to the HPRA, since 22 November 2017
this requirement was extended to include non-serious reports. This change to reporting
requirements largely accounts for the increase in the volume of reports received.
HPRA Annual Report 2017
15
- In the context of the changed reporting requirements, 76% of all adverse reaction reports
received by the HPRA in 2017 were reported by MAHs, with a further 1.5% reported in the
context of ongoing clinical trials. It is important to note that these reports will have initially
been notified to companies by healthcare professionals, patients or consumers. The remainder
of the reports received (22.5%) were submitted directly to the HPRA by healthcare
professionals and members of the public with almost half of these submitted through the
HPRA’s online reporting system.
- Medicines subject to additional monitoring accounted for 26% of the reports submitted.
- The medicines most frequently included in reports to the HPRA accounted for 78% of the
adverse reaction reports received in 2017 (see table). It is important to note that the place of a
medicine on this list cannot be taken as an indicator of safety or risk. The number of reports
received cannot be used as a basis for determining the incidence of a reaction as neither the
total number of reactions occurring, nor the number of patients using a medicine, is known.
Suspect Medicine(s) / Class of Medicines Number of
Reports*
Antineoplastics, including immunomodulating medicines,
monoclonal antibodies and endocrine medicines
1854
Psycholeptic medicines 453
Anti-infective medicines, including antibacterials, antimycotics,
antivirals and immunoglobulins
413
Vaccines 294
Medicines for the treatment of bone disease 193
Cardiovascular medicines, including antihypertensives and lipid
lowering agents
166
Medicines used in Diabetes 155
Medicines used to treat Parkinson’s Disease 149
Antithrombotic medicines 136
Respiratory medicines 125
2835 2884 2810
3264
4402
0
500
1000
1500
2000
2500
3000
3500
4000
4500
5000
2013 2014 2015 2016 2017
Adverse Reaction Reports
HPRA Annual Report 2017
16
- Of the new adverse reaction reports received by the HPRA in 2017, 262 patients were reported
to have died while on treatment. The table below outlines the medicines or class of medicines
associated with the highest number of reports. In many of these cases, the patients had
significant underlying illness and were treated with multiple medicines and/or surgery which
may also have contributed to the outcome. In addition, many of these cases were influenced
by disease progression or other complications unrelated to the medicine. The majority were
associated with medicines subject to close monitoring, those used in the management of
severe underlying medical conditions, in patient support programmes and special patient
monitoring programmes.
Suspect Medicine(s) / Class of Medicines Number of
Reports*
Antineoplastics, including immunomodulating medicines,
monoclonal antibodies and endocrine medicines
114
Psycholeptic medicines 31
Antithrombotic medicines 19
Analgesic medicines 16
Anti-infective medicines, including antibacterials, antimycotics,
antivirals and immunoglobulins
15
Parenteral nutrition preparations 10
Cardiovascular medicines, including antihypertensives and lipid
lowering agents
8
Respiratory medicines 6
Medicines for the treatment of bone disease 5
Radiopharmaceuticals for treatment of cancers 4
*Please note that in some cases treatment may have involved more than one medicine from the groups
listed.
The HPRA also plays a key role in monitoring the safety of medicines on the Irish market via our
vigilance assessment and risk management activities. This incorporates our contribution to the
work of the Pharmacovigilance Risk Assessment Committee (PRAC) at the EMA. During 2017, the
HPRA:
- Continued our involvement in the work-sharing initiative for signal detection within the EU
acting as lead Member State for the monitoring of 54 nationally-authorised active substances.
Serving as PRAC rapporteur, we were also responsible for the further management of any
signals detected in relation to 44 centrally authorised medicines (containing 28 active
substances / combination of active substances).
- Participated in the EU periodic safety update report (PSUR) single assessment procedure,
contributing to the evaluation of 941 PSURs and leading the single EU assessment for 29 of
these procedures.
- Participated as a concerned Member State in 13 newly initiated safety referrals seven of which
reached a conclusion during the year.
- Contributed to the review of 154 risk management plans (newly approved or updated)
submitted via national, mutual recognition, decentralised and centralised procedures. We also
provided assessment input to 348 post authorisation safety study procedures (protocols,
reports and other post authorisation safety-related measures).
HPRA Annual Report 2017
17
The inspections and audits programme focuses on ensuring industry compliance with relevant
standards and legislation. This year, there were:
- 106 good manufacturing practice (GMP) inspections were conducted at sites that produce
human medicines or active substances.
- 183 good distribution practice (GDP) inspections at wholesalers and distributors;
- 13 good clinical practice inspections;
- 4 pharmacovigilance inspections.
The HPRA’s risk based sampling and analysis programme is part of our monitoring of the quality
and safety of medicines on the Irish market or which are manufactured in Ireland for export. It
involves the analytical testing of products and / or examination of their packaging and labelling. A
total of 288 samples were taken under the programme in 2017. This included:
- The examination of the packaging and labelling of 136 medicines and other products
available on the Irish market. A total of 35 non-compliances were identified including Braille-
related issues, non-compliant packaging and labelling, and the absence of updated safety
information. Appropriate follow-up actions were taken in each case.
- Additionally, 128 medicines and other product samples for human use were sent for analytical
testing during the past year. Although the majority of the samples tested were compliant with
their specifications, a number of out-of-specification results were also obtained. The most
frequent of these related to product appearance not being in accordance with the
specification. Again, appropriate follow-up actions were taken in each case.
The quality defect and recall programme investigates, on a risk basis, reports of suspected quality
defects in medicines and in their related active substances. It also co-ordinates recalls from the
Irish market. Quality defects pertaining to 650 medicines for human use were reported or
identified in 2017. The risk classifications that were assigned, along with the corresponding figures
for the previous two years, are outlined in the accompanying table.
As in previous years, companies (65%), including manufacturers, distributors and/or authorisation
holders, and other competent authorities (27%) were the primary sources of received reports.
In certain cases, it may be deemed necessary to withdraw, or recall, medicines from the Irish
market in order to protect public health. During the year, 82 medicine recalls occurred
representing a 59% decrease when compared to 2016 (when an unusually high number of recalls
occurred due to distribution issues). Overall, the most common causes of recalls during 2017
were:
Year 2015 2016 2017
Critical quality defects 213 119 124
Major quality defects 218 331 196
Minor quality defects 301 382 327
Number of reports not justified 5 3 3
Total Number Quality Defects 737 835 650
HPRA Annual Report 2017
18
Cause of Recall Human Medicines
Erroneous distribution activities 11
Stability issues 11
Non-compliance with variations 7
Lack of sterility assurance 9
Other non-compliance with GMP 6
Non-compliance with SPC/printed artwork 5
Non-compliance with specifications 5
Adverse reactions or changes in benefit/risk ratio 4
Primary/secondary packaging component issues 4
One of the mechanisms used by the HPRA to aid continuity of supply to the market place in the
event of a medicine shortage includes the granting of a temporary authorisation for a batch of a
medicine known as a ‘batch specific request’. In 2017, there were 115 requests received.
The HPRA monitors the general retail sale of consumer healthcare products in outlets such as
grocery shops, health food shops and, where necessary, pharmacies. This year, 73 cases, some of
which involved multiple products, were investigated. Of these,
- 34 related to the sale of medicines that did not carry a valid registration number or
authorisation number for the Irish market.
- 22 related to proactive monitoring of compliance of retailers in the sale of certain medicines
with additional restrictions; and
- 17 related to the sale of products that had been incorrectly classified as non-medicines by
those placing them on the market.
A total of 57 medicines that did not carry a valid registration or authorisation for the Irish market
were removed from sale with 11 of these medicines subject to prescription control.
Three regulatory compliance inspections were conducted at the premises of marketing
authorisation holders to determine the level of compliance with the legal requirements for the
marketing and advertising of medicines.
The advertising compliance programme monitors and reviews advertising and promotion
activities by the industry for compliance with the legislation. This year 334 advertisements were
reviewed, and non-compliances, including both major and minor issues, were identified in 160 of
these. In all cases, the HPRA oversaw the necessary corrective and/or preventative actions for
those issues, where relevant. Eight advertisements were recalled. (The HPRA has published a
standalone report available from our website which provides an overview of the main elements of
the advertising compliance programme for 2017).
Under our enforcement programme:
- The HPRA detained 948,915 dosage units (including tablets, capsules and vials) of falsified and
other illegal medicines last year compared to 673,906 units in 2016 – an increase of more than
40%. The products detained, through both ongoing surveillance and targeted intelligence
based operations, included anabolic steroids (47%), sedatives (23%) and erectile dysfunction
medicines (13%). There was a significant rise in the number of anabolic steroids detained
HPRA Annual Report 2017
19
rising from 109,006 in 2016 to 449,411 dosage units in 2017. Separately, a total of 3,866
enforcement cases were initiated, compared to 4,054 in the previous year.
- In one operation of particular significance, over 60,000 vials labelled as containing anabolic
steroids were detained as part of a joint operation carried out with An Garda Síochána and
Revenue’s Customs Service at a number of locations in County Donegal. Other medicines,
including human growth hormone and products indicated for erectile dysfunction, were also
found. The total value of illegal medicines detained was estimated to be in excess of €2
million.
- We initiated six prosecution cases and issued six voluntary formal cautions. Prosecutions are
taken where the HPRA considers that there is a significant risk to public health. The 2017
prosecutions related to the unauthorised supply of prescription medicines, including anabolic
steroids and erectile dysfunction products. The HPRA also supports prosecutions brought by
the Director of Public Prosecutions in relation to the illegal supply of medicines.
- The HPRA, in partnership with Revenue’s Customs Service and An Garda Síochána, detained
over 200,000 units of illegal prescription medicines in Ireland, valued at over €850,000, as part
of the Interpol-coordinated Operation Pangea X. The products detained included significant
volumes of anabolic steroids, sedatives and erectile dysfunction medicines. Nationally, the
week-long operation also resulted in two arrests, the investigation of 38 websites and eight
social media pages being taken offline. Operation Pangea X was an international week of
action across 123 countries to tackle the online sale of counterfeit and illicit medicines and
highlight the dangers of buying medicines online.
LEGISLATION AND REGULATION
The new Clinical Trial Legislation, Regulation EU No 536/2014, was originally intended to be
implemented throughout the EU by October 2018 but this timeline has been deferred due to
delays in building the online portal for applications at the European Medicines Agency.
Notwithstanding these European delays, some national activities have been progressed during
2017:
- We engaged with the Department of Health and HIQA regarding the implementation of the
Regulation and the development of national legislation.
- We developed a pilot scheme (for commencement in January 2018) for simultaneous
submission of applications to both the HPRA and ethics committee which will enable
preparation for implementation of the Regulation. Guidance and templates for sponsors were
published in December.
- We actively participated in the European voluntary harmonisation project which is similar to
the approval process for clinical trials under the planned new legislation (see page 12).
From 9 February 2019, under the Falsified Medicines Directive, medicines must carry special safety
features in the form of an anti-tamper device and a barcode containing ‘unique identifiers’
(including a serial number) to enable the authenticity of the pack to be checked prior to
dispensing. This year:
- Updates in respect of the national implementation and introduction of these measures,
including the establishment of the National Medicines Verification Organisation’s repository,
were given to industry stakeholders at the HPRA’s Good Manufacturing Practice (GMP) and
Good Distribution Practice (GDP) information days which took place on 7 and 8 February.
- The EU working group, led by the HPRA, on supervision of the national repositories of unique
identifiers developed a work plan for the project with agreed outputs and timelines for
completion.
HPRA Annual Report 2017
20
We participated in audit teams as part of the Joint Audit Programme (JAP) of GMP inspectorates of
competent authorities. This also included the allied Joint Reassessment Programme (JRP) of the
Pharmaceutical Inspection Co-operation Scheme (PIC/S).
STAKEHOLDERS AND PARTNERS
As previously outlined (see page 13), the HPRA appeared before the Committee on Health in early
March along with officials from the Department of Health to discuss the report – Cannabis for
Medical Use: A Scientific Review. The HPRA Chief Executive, who was accompanied by the Clinical
Assessment Manager, outlined the report findings and recommendations which were finalised
following input from an expert working group comprising relevant clinical experts and patient
representatives. The HPRA representatives provided responses to a number of queries from the
Committee members.
In May, the HPRA’s Director of Human Products Monitoring joined experts from the Department
of Health, the Royal College of Physicians in Ireland and the HSE in addressing members of the
Committee on Health on the issue of vaccine uptake levels. Among the topics discussed were the
huge positive public health impact of vaccination, how the safety of vaccines are monitored on an
ongoing basis, and issues related to the fall in the numbers receiving the HPV vaccine in the
recent past.
As in recent years, the HPRA delivered a programme of presentations and talks at external
stakeholder events such as meetings, seminars, conferences and training courses. Such
presentations provide stakeholders such as healthcare professionals and regulatory professionals
with access to relevant, up-to-date information. In addition, a programme of presentations was
delivered to undergraduate and postgraduate students studying courses related to the role of the
HPRA. A full list of all presentations delivered during 2017 relevant to human medicines is
provided in Appendix 2.
Publications and Information
- The Drug Safety Newsletter provides important safety information to healthcare professionals
with hyperlinks to product information and other relevant documents on the HPRA and EMA
websites. Seven issues of the newsletter were published and distributed to registered
healthcare professionals, all of which are accessible from the HPRA website. A full index of
topics covered during the past year is included in Appendix 3.
- Risk communications:
o During 2017, 106 new or updated educational materials were approved by the HPRA
in addition to 21 direct healthcare professional communications.
o The PRAC monthly agendas, minutes, meeting highlights, notifications of safety
reviews and signals were also made available via our website.
- There were a number of articles provided for inclusion in the monthly MIMs (Ireland)
publication in addition to articles for the Irish Medicines Formulary. The full list of topics
covered in these articles is included in Appendix 3.
- The Medicinal Products Newsletter provides regulatory news and updates for those working
in the pharmaceutical industry. Three editions were published on our website in 2017 and are
available to download from the ‘Publications’ section.
- Three new guidance documents relevant to human medicines were published in 2017 and are
available to download from our website:
o Guide to Scientific and Regulatory Advice for GXP activities
o Guide to Clinical Trials Regulation (EU) No. 536/2014 Pilot Project
o HPRA Brexit Guidance
HPRA Annual Report 2017
21
HPRA information seminars and training events provide regulatory guidance and updates to a
range of stakeholders. Our programme of events in 2017 included:
- The biennial good manufacturing practice (GMP) and wholesale distribution information days
which were held on consecutive days in February and attracted a combined attendance of
almost 650 industry representatives.
- A GMP inspector training course, organised by the HPRA on behalf of PIC/S, which took place
in Dublin from 23 to 27 October and was attended by 34 GMP inspectors from 17 countries.
- An information day in November for stakeholders on the HPRA’s regulatory compliance
inspection and advertising programmes. This was attended by over 140 industry
representatives.
HPRA Annual Report 2017
22
Medical Devices
As the national competent authority for medical devices, the HPRA carries out a range registration,
surveillance, monitoring and compliance activities. Our aim is to make sure that these products
perform as intended and do not compromise the health and safety of the patient or the person using
them.
AUTHORISATION AND REGISTRATION
The HPRA is focused on ensuring effective and consistent designation and oversight of notified
bodies at national and European level. In 2017, we:
- Continued our schedule of oversight of the notified body in Ireland based on ongoing
assessment, surveillance and observed audits.
- Provided expert assessors to participate in four EU joint assessments of notified bodies based
in other European countries. Since the scheme’s introduction in 2013, the HPRA has provided
the highest number of expert assessors to this programme compared to other EU countries.
- Continued to provide leadership and support development of EU coordination of notified
body designation and oversight by acting as the deputy chair for the EU Notified Body
Operations Group (NBOG) and participated in the core EU Joint Assessment Coordination
Group (JACG).
- Identified and prioritised development of systems and resources at national and EU level to
allow, from November 2017 onwards, timely and effective designation of notified bodies
required under the new EU Device Regulations (EUDR).
Supporting innovation and research of new technologies is a key strategic priority for the HPRA
devices team. In 2017, this involved:
- The review of applications to conduct clinical investigations of medical devices in Ireland. The
number of clinical investigations taking place continues to increase with nine new applications
and six amendments to ongoing investigations received in 2017. The HPRA continue to focus
on this area to ensure regulatory requirements and processes are clear to potential applicants.
- Organising a medical device innovation workshop in Galway hosted by the NUIG Clinical
Research Facility in conjunction with the CURAM and BioInnovate facilities. The workshop was
attended by over 50 innovators, researchers and clinicians.
- Encouraging engagement during product development and innovation of medical
technologies. During 2017, we met with 16 groups of innovators (13 preliminary and three
pre-submission meetings).
- Supporting the work of the HPRA Innovation Office by responding to around 40% of all
queries received.
- Presenting and participating in innovation sessions at a variety of conferences and workshops
including the EuroPCR conference in Paris.
In 2017, the HPRA received 31 registrations of new organisations manufacturing self-declared
medical devices in Ireland. A total of 362 new self-declared medical devices were also registered.
Additionally, during the year we developed a comprehensive listing of economic operators within
the medical device sector in Ireland (manufacturers, authorised representatives, distributors) to
allow for better planning and coordination of our market surveillance activities.
HPRA Annual Report 2017
23
SAFETY AND QUALITY
We continue to develop and reinforce our market surveillance activities, with particular emphasis
on proactive rather than reactive actions. Of note in 2017:
- We launched a new lifecycle market surveillance strategy and planning mechanism to ensure
continued safety and performance of devices throughout their lifetime.
- We led or participated in various elements of both technical work packages of the EU Joint
Action on Market Surveillance (JAMS) of medical devices initiative which is funded by the
European Health Programme. In 2017, we hosted two workshops in Dublin and attended a
further two in London involving delegates from 17 European countries with a view to:
o developing a process for coordination of EU level market surveillance issues;
o identifying a single secure communication platform for information sharing
o developing a process, best practices and training for joint manufacturer inspections;
o developing a process for prioritisation of devices requiring common specifications.
- We continued our participation in the European COEN Joint Action 2014 on reusable and re-
sterilisable medical devices. In 2017, seven Irish based manufacturers were audited as part of
the programme. One of these audits was conducted jointly with assessors from other Member
States. In addition, the HPRA participated in one joint audit of a manufacturer in another
Member State during 2017.
- A total of 43 COEN notices were sent to the European network relating to medical device
compliance concerns arising from HPRA activities while five information notices were
published in relation to medical device issues.
- There were 1,281 market surveillance cases* undertaken in 2017. The decrease in cases, when
compared to 2016, is the result of a 26% decrease in the number of EU notifications received
by the HPRA relating to notified body certificates. This decrease is likely as a result of the
success of the joint assessment scheme. During 2017, the HPRA increased the number of
other market surveillance cases by 24%, including technical file and clinical evaluation review
cases. Such cases are more resource intensive and complex than certificate notification cases.
*Please note that from the start of 2014, the HPRA changed the way we define market surveillance cases
and so the figures in the graph have been adjusted* by applying the pre-2014 definition to allow for
comparison with 2012 and 2013 figures.
We continued to focus our vigilance activities during 2017 on the areas of user reporting and
dissemination of HPRA medical device safety communications. This included:
865 902
1283
1448
1281
0
200
400
600
800
1000
1200
1400
1600
2013 2014 2015 2016 2017
Market Surveillance Cases
HPRA Annual Report 2017
24
- The receipt and assessment of 2,339 medical device vigilance reports representing a 6%
increase on 2016. Of the reports notified to the HPRA, 12% came from users of medical
devices. Manufacturers accounted for 62% of reports received in 2017 while 30% came from
other competent authorities.
- There were 278 product removals conducted in Ireland during 2017. The HPRA also issued 89
national competent authority reports.
- Surgical devices, orthopaedic devices and infusion devices accounted for 42% of the total
vigilance reports. Reports continue to be received relating to diagnostic imaging and
radiotherapy devices. In addition, we continue to receive reports relating to revision
procedures associated with the ASR Articular Surface Replacement and ASR XL Acetabular
system manufactured by DePuy. During the year, we also continued development work on
signal detection of medical device issues.
As part of its market surveillance activities, the HPRA undertakes proactive and ‘for-cause’ audits of
manufacturers, notified bodies and authorised representatives with the objective of monitoring
compliance of devices emanating from Irish based organisations. During 2017, 22 audits were
performed at both medical device manufacturers and authorised representative facilities, of which:
- three were for cause audits, one of which was in the US;
- eight were reactive audits based on vigilance / market compliance issues;
- sixteen were audits based on proactive market surveillance projects – including the EU joint
action (COEN JA2014);
- two audits were conducted joint with other EU and international regulatory authorities.
433
348
287
239
177
7962 62 61 57 53
0
50
100
150
200
250
300
350
400
450
500
Vigilance Reports Received - Top 10 Product Types
HPRA Annual Report 2017
25
LEGISLATION AND REGULATION
Following publication of two new European Regulations on medical devices in May 2017, the HPRA
continued its work to help ensure an effective and timely implementation of these EU Device
Regulations (EUDR) at national and European level. This included:
- Developing internal resources, procedures and systems to ensure notified body requirements
could be applied at national level from November 2017.
- Assisting the Department of Health in the development of relevant national legislation (S.I. No.
547 of 2017) to nominate the HPRA as the National Competent Authority (NCA) for medical
devices and the authority responsible for notified bodies in Ireland.
- Preparing detailed information relating to the new requirements with respect to the need for
national legislation, the timelines and impact on existing national legislation.
- Contributing to the European development of the secondary legislation required to enable
notified body provisions to become applicable on time from 26 November 2017.
- Accepting nominations to represent Ireland at the newly established EU Medical Device
Coordination Group (MDCG) and as part of the Regulatory Committee which decides on
secondary legislation for the new EUDR. The first meeting of the MDCG took place in late
November 2017.
- Participating in the EU steering group for development of the new European database (MDR
EUDAMED) envisaged by the new Regulations. The HPRA also participated in a number of the
associated technical working groups on certificate & registration, UDI and clinical aspects with a
view to developing the system requirements and functional specifications.
- Participating in the development of Competent Authorities for Medical Devices (CAMD)’s
Frequently Asked Questions on transition to the new legislation, which are now published on
the CAMD website.
We continued to engage with the Department of Health throughout 2017 on policy and legislative
issues. Of note, a national fee-based funding model for medical devices was implemented in
January to recover the costs associated with our medical device activities. Fees were confirmed for
all economic operators (manufacturers, authorised representatives and distributors) in Ireland.
Further information and feedback received from the sector obtained during 2017 will be used to
inform future revisions to the model which will be subject to further public consultation during
2018.
The HPRA continues to play a significant role in the development of EU regulatory systems and
mechanisms to promote coordination, cooperation and consistency. During 2017, we:
- Participated as a member of the Executive Group of the Competent Authorities for Medical
Devices (CAMD) network. This group has successfully worked in partnership with the EU
Commission over the last number of years to develop the regulatory system in Europe.
- Proposed the establishment of an Implementation Task Force (ITF) at the CAMD to identify
priorities for EU work on implementation, provide a forum for discussion and consensus on
interpretation of the new Regulations, and establish a mechanism for engagement with
stakeholders on implementation. During 2017, the HPRA acted as interim chair for this
taskforce, which published the European Implementation Roadmap in October.
- Contributed to the design and delivery of training on notified body joint assessments to
authority expert assessors at the EU Commission’s premises in Grange, Co. Meath.
- Continued to lead the work of the clinical investigation and evaluation working group, acting as
the co-chair of the group along with the EU Commission.
The HPRA continued to participate actively in initiatives to promote regulatory convergence and
harmonisation of medical devices globally through the International Medical Device Regulators
Forum (IMDRF). This involved:
HPRA Annual Report 2017
26
- Participation in the IMDRF Management Committee as part of the European delegation (along
with the EU Commission, France and Germany).
- Continuing to act as the IMDRF secretariat for the National Competent Authority Report (NCAR)
Exchange programme. We also participated in a number of different IMDRF working groups
including the group on regulated product submissions (RPS) and medical device registries.
- On behalf of the EU, we officially observed two Medical Device Single Audit Programme
(MDSAP) assessments of manufacturing sites witnessing the performance of the auditing
organisations. The HPRA also observed the assessment by a MDSAP consortium of an applicant
auditing organisation.
- Contributing to briefings for the EU Commission for the purposes of the MDSAP Regulatory
Authority Committee discussions and also encouraged discussions at EU level to further
Europe’s future engagement in the programme.
We have an ongoing focus on horizon scanning and on developing our capabilities to effectively
regulate new and emerging technologies. During 2017:
- Team members researched and attended training courses in a number of medical technology
areas including software, cybersecurity and additive manufacturing.
- The Advisory Committee for Medical Devices (ACMD) established a new subgroup on medical
device software and cybersecurity with a view to identifying challenges and regulatory /
guidance needs.
- The HPRA also assumed a leadership role in Europe, chairing the software classification
subgroup of the EU classification borderline working group.
- We presented at a number of conferences and engaged with companies adopting additive
manufacturing techniques (such as 3D printing) and were part of a cross-organisational horizon
scanning project to examine and report on the regulatory aspects of additive manufacturing.
STAKEHOLDERS AND PARTNERS
We continued to invest in stakeholder engagement and communication with medical devices
stakeholders throughout 2017. This involved the promotion of direct reporting of incidents and
medical devices issues by device users and members of the public. We also continued our
engagement with health services and healthcare professionals to encourage reporting and raise
awareness of the roles and activities of the HPRA. Work was undertaken with the HSE to identify
mechanisms and identify appropriate individual contacts to facilitate dissemination of safety
information on medical devices to the relevant health services/users (designated person and
vigilance liaison officers). We also continued to promote the adoption and communication of the
HPRA step-by-step guide to user reporting which is targeted at healthcare providers.
The HPRA undertook a number of communication initiatives to raise awareness of the impact and
requirements being introduced as a result of the new EUDR. During 2017, we:
- Established a dedicated section on HPRA website regarding EUDR. This incorporated
stakeholder guidance and application forms for notified bodies to reflect the new requirements
for designation to EUDR by the November timeframe.
- Published a dedicated newsletter and other information resources to raise awareness of specific
aspects of the Regulations and its practical application. These included specific information
leaflets targeting medical device innovators and also the cosmetic industry (given the inclusion
under the new device Regulations of certain aesthetic products).
- Contributed to the development and actively participated in two European stakeholder days on
the new EUDR hosted by the EU Commission and CAMD.
- Provided briefings, advice and workshops on the new Regulations to a range of different
stakeholders including notified bodies and distributors.
HPRA Annual Report 2017
27
Throughout the year, we engaged in ongoing strategic, operational and communication initiatives
on a bilateral and multilateral basis with European and international authorities, and the EU
Commission. We also further developed our bilateral partnerships with a number of those
authorities. In addition, we participated in operational and strategic discussions on developing
cooperation between the CAMD and the Heads of Medicines Agencies (HMA) networks.
The HPRA continues to deliver a programme of presentations and talks at a range of external
stakeholders. A full list of all presentations related to the regulation of medical devices that were
delivered during 2017 is provided in Appendix 2.
Medical Devices: Key Figures
2015 2016 2017
Lead Competent Authority role on specific vigilance issues 74 98 89
NCARs and vigilance related communications 79 116 96
Vigilance cases received/opened 2,140 2,242 2,339
Field safety notices uploaded 474 476 519
Medical device safety notices 33 46 44
Medical device targeted healthcare professional communications 11 33 23
NCARs managed as IMDRF NCAR secretariat - 18 8
COEN reports (market surveillance and vigilance) to EU network 12 45 44
Medical device information notices 3 0 5
Market surveillance cases (unadjusted) 324 335 411
Notifications relating to notified body certificates 959 959 844
Classification requests 54 35 51
Compassionate use applications 3 5 5
Medical device free sale certificates 2,601 2,122 2,371
Medical device queries received 459 477 496
HPRA Annual Report 2017
28
Blood, Tissues and Organs
The HPRA is responsible for monitoring the safety and quality of blood and blood components and of
tissues and cells. Along with the HSE, we are joint Competent Authority for organs intended for
transplantation.
AUTHORISATION AND REGISTRATION
The authorisation of blood establishments, tissue establishments and organ procurement
organisations / transplantation centres permits those facilities to carry out specified activities. The
total number of authorisations in place at year end for the past five years is presented by category in
the accompanying table.
Number of Authorisations 2013 2014 2015 2016 2017
Blood establishments 4 4 3 3 3
Tissue establishments 23 24 24 25 25
Organ procurement/transplantation 0 0 4 4 4
SAFETY AND QUALITY
Following collaboration with the National Haemovigilance Office (NHO), we submitted an annual
report of serious adverse reactions and events to the EU Commission during 2017. The report
reflected information received by the NHO in 2016 and included information on 61 serious adverse
reactions and 152 serious adverse events which met the mandatory legislative reporting
requirements.
We also submitted an annual report on serious adverse reactions and events associated with
tissues and cells to the EU Commission during 2017. The report reflected information received in
2016 and consisted of some 112 reports, 103 of which met the legislative reporting requirements,
including seven serious adverse reactions and 96 serious adverse events.
The Joint Action on Vigilance and Inspection for the Safety of Transfusion, Assisted Reproduction
and Transplantation (VISTART) promotes and facilitates the harmonisation of inspection,
authorisation and vigilance systems in the EU for blood, tissues and cells used in transfusion,
transplantation and assisted reproductive technology. As part of the HPRA’s contribution to
VISTART activities, we are leading Work Package 9 which involves a voluntary programme of inter-
member state inspection systems auditing. Consequently, we carried out a pilot audit in Q3 using
tools developed under this work package. In Q4, we also conducted an audit of the relevant
Latvian authority as part of the pilot phase of the VISTART project.
We continued to liaise with the HSE lead and colleagues from Organ Donation and Transplant
Ireland (ODTI) in relation to our respective roles under EU and national legislation on the Quality
and Safety of Human Organs intended for Transplantation. During 2017, this included:
- The exchange of relevant information on serious adverse reactions and events. During 2017,
the HPRA received 13 reports of serious adverse reactions and events associated with organ
donation / transplantation;
- The ongoing review of procedures and guidance incorporating the finalisation of updates to
the report form which were completed by year end;
- The submission of proposals to the OTDI in respect of updating the framework for quality and
safety.
HPRA Annual Report 2017
29
As part of our regulatory role, the HPRA inspects relevant establishments, organisations and
centres to monitor compliance with applicable EU guidelines on the quality and safety of blood,
blood products, tissues and cells, and human organs intended for transplantation. Our inspection
programme in 2017 consisted of:
- 19 tissue establishment inspections of which four were non-routine;
- 7 routine inspections of blood establishments; and
- 1 routine inspection of an organ establishment.
LEGISLATION AND REGULATION
As part of our ongoing contribution to the review of relevant legislation, we provided feedback to
the Department of Health on draft SIs for transposing EU Directives on coding and import for
human tissues and cells.
In relation to assisted human reproduction, we engaged with the Department of Health during
2017 to discuss the development of assisted human reproduction legislation including the
proposed regulatory agency. We also engaged in respect of the commencement of parts 2 and 4
of the Children and Family Relationships Act.
HPRA Annual Report 2017
30
Veterinary Medicines
Our role is to grant licences for veterinary medicines subject to a review of their safety, quality and
effectiveness. We continuously monitor their use in animals once they become available on the market
in addition to authorising clinical field trials and inspecting / licensing manufacturing sites.
AUTHORISATION AND REGISTRATION
There are a number of routes through which a veterinary medicine can be authorised by the HPRA.
These include the national procedure, the mutual recognition procedure (MRP) and the
decentralised procedure (DCP). The following applications were issued by the HPRA during 2017:
- 10 new national applications;
- 75 new applications made under the DCP;
- 28 new applications made under the MRP.
We acted as reference (lead) Member State for the assessment of one of the MRPs and 30 of the
DCPs. We also issued five applications as RMS under the repeat use procedure.
The centralised route administered by the EMA is another mechanism whereby veterinary
medicines can be authorised in Ireland. In 2017, the HPRA issued 16 cases as rapporteur or co-
rapporteur for veterinary medicines. An additional 18 new medicine applications were issued
through the centralised route where we were neither the rapporteur nor co-rapporteur.
By end of year, there was a record total of some 1,700 veterinary medicines authorised for the Irish
market.
During 2017, the HPRA acted as co-ordinator for three requests under the EMA scientific advice
procedure.
Medicine shortages continue to be an issue for many veterinary practitioners tasked with treating
many different species and conditions. Problems of non-availability can arise from a number of
issues and different solutions are needed depending on the issues involved. During 2017:
- We conducted planned twice yearly reviews of AR18 and AR16 lists. The HPRA strategy is to
review incoming requests and seek Irish authorisation where practicable.
- Carried out gap analysis and prioritised applications linked to shortages.
- Meetings were held with the Department of Agriculture, Food and the Marine to discuss
shortages related issues. There was agreement to develop an inter-departmental process in
respect of potential shortages arising from Brexit.
- Communicated and met with applicants regarding transfer of reference member state (RMS)
to Ireland. We also revised the relevant procedure and established a register of products for
transfer.
- We worked closely with EU competent authorities to enable the use of common packs and
carried out a survey to explore dual labelling interest in other Member States.
Authorisation and registration: Key figures
2015 2016 2017
Classification enquiries 21 16 11
Clinical trials 0 1 2
HPRA Annual Report 2017
31
New centralised as (co-)rapporteur 11 11 16
New MR/DCP as RMS 15 14 30
New MR/DCP as CMS 93 78 44
New homeopathic applications 6 0 3
New national applications 5 8 8
Renewals, national and MR 88 100 108
Variations, national and MR 1431 1341 1366
Manufacturers of veterinary medicines 25 24 20
Export certificates 99 155 111
SAFETY AND QUALITY
The operation of a national pharmacovigilance system for veterinary medicines is dependent on
the submission of reports by veterinarians, pharmacists, licensed merchants and others involved in
dispensing or using the medicines concerned. These reports may be submitted either directly to
the HPRA or to the companies marketing the medicines. The companies, in turn, must relay the
data to the HPRA.
Over the course of 2017, we received 397 national reports of suspected adverse events to
veterinary medicines with the vast majority of reports, as in previous years, received from
pharmaceutical companies.
We evaluated 630 periodic safety update reports (PSURs) which incorporated the assessment of
individual medicines on the market in Ireland as well as a work-sharing initiative where we led, or
contributed to, the assessment of a class of veterinary medicines for the European Union.
Containment of the development of antimicrobial resistance (AMR) is essential for public and
animal health. Our work in this area includes the collection of annual information on the sale of
veterinary antibiotics from each marketing authorisation holder. This information, which is included
in the European Surveillance of Veterinary Antimicrobial Consumption (ESVAC), is important as it
allows us to benchmark our usage rate against those of our European neighbours and to follow
271300
435
337
397
0
50
100
150
200
250
300
350
400
450
500
2013 2014 2015 2016 2017
Adverse Event Reports
HPRA Annual Report 2017
32
any developing trends. The data show that due to a variety of factors there are significant
fluctuations in sales annually and, consequently, that a clear trend is not identifiable.
Veterinary antibiotic use 2012 2013 2014 2015 2016
Tonnes sold 97.4 99.1 89.4 96.9 103.4
Additionally in 2017, we continued our participation in the National Interdepartmental
Antimicrobial Resistance Consultative Committee which in October published ‘Ireland's National
Action Plan on Antimicrobial Resistance 2017-2020’.
The analytical testing of products is a key component of the HPRA’s risk based sampling and
analysis programme. A total of 31 samples of veterinary medicines were taken under the
programme in 2017 and all were subject to laboratory testing. Although the majority of the
samples tested were compliant with their specifications, a number of issues, such as the crumbling
of tablets, were noted. Appropriate follow-up actions were taken as necessary.
We investigate, on a risk basis, reports of suspected quality defects in medicines and active
substances, and co-ordinate subsequent recalls from the Irish market where necessary. There were
48 quality defects pertaining to medicines for veterinary use reported or identified in 2017. The risk
classifications that were assigned, along with the corresponding figures for the previous two years,
are outlined in the accompanying table.
Companies, including manufacturers, distributors and/or authorisation holders, accounted for 64%
of the reports received with the balance received from other competent authorities.
In certain cases, in order to protect animal and / or public health, it is deemed necessary to
withdraw, or recall, a veterinary medicine from the Irish market. In 2017, seven recalls of medicines
occurred which was one less than the previous year. Of these, three were recalled due to stability
issues.
Our inspections and audits programme focuses on ensuring industry compliance with relevant
standards and legislation. In 2017, there were:
- 12 good manufacturing practice (GMP) inspections conducted at sites that produce / test
veterinary medicines;
- 2 pharmacovigilance inspections.
Year 2015 2016 2017
Critical quality defects 1 7 5
Major quality defects 8 12 13
Minor quality defects 25 22 30
Number of reports not
justified 1 0
0
Total Number Quality Defects 35 41 48
HPRA Annual Report 2017
33
LEGISLATION AND REGULATION
We continued to engage with the Department of Agriculture, Food and the Marine in respect of
the proposed new EU veterinary medicines legislation. Meetings were held to review the proposals
and we presented feedback on each Commission revision. We also met before year end to
consider the European Council discussions on the new legislation. The Department participates at
Council meetings.
STAKEHOLDERS AND PARTNERS
As part of our ongoing stakeholder engagement, in 2017:
- We conducted a survey during Q2 in respect of outgoing MR/DCP applications to determine
stakeholder perceptions of the HPRA‘s service levels and performance, and to assess their
communication needs and expectations. Analysis of the results were completed by year end
and the findings will be used to inform future service provision and communications.
- We held meetings with a number of stakeholders during the year as part of our review and
audit of the current level of national regulatory and scientific advice provision at each stage of
product development.
- We are committed to participating in activities that promote pharmacovigilance reporting, in
particular with respect to food-producing species. During the year, we developed a training
proposal and submitted a draft training module to a third level institute for review and
consideration.
- As part of our commitment to enhance our stakeholder communication on safety issues, we
developed and published a number of safety notices on our website in relation to vaccine
shortages and topics including euthanasia, zinc oxide and monitoring of medicines.
Throughout 2017, we continued our involvement across the EU regulatory network which includes
active participation at the EMA and the HMA. Of particular note, Dr David Murphy continued to
serve as Chair of the EMA’s Committee for Medicinal Products for Veterinary Use (CVMP) following
his election in 2016.
As in recent years, we delivered a programme of presentations to veterinarian students and
veterinary nursing students on the role of the HPRA and the promotion of veterinary
pharmacovigilance. We also presented at a number of industry stakeholder events. A full list of all
presentations delivered during 2017 is provided in Appendix 2.
We continued during 2017 to publish relevant content in our Medicinal Products Newsletter. This
newsletter provides updates for those working in the veterinary medicines sector on Irish and
European legislation, new / revised HPRA regulatory publications and stakeholder events such as
information days. Three editions were published on our website in 2017 and are available to
download from the ‘Publications’ section.
We also contributed a number of articles to the Veterinary Ireland Journal and the It’s Your Field
publication. Details are included in Appendix 3.
HPRA Annual Report 2017
34
Scientific Animal Protection
The HPRA is the competent authority in Ireland responsible for the implementation of EU legislation
(Directive 2010/63/EU) for the protection of animals used for scientific purposes.
AUTHORISATION AND REGISTRATION
The HPRA carries out evaluations of applications for the authorisation of research establishments
and projects in addition to evaluating applications from individuals to allow them to conduct
procedures or euthanasia of animals. As shown in the accompanying table, there was an increase
in both the total number of individuals and projects authorised in 2017. Please note that the
higher level of individual authorisations during 2013 and 2014 was due to the legal requirement
for existing establishment personnel to apply for individual authorisations, which are valid for five
years, before the end of 2014.
In October, we published the fourth annual statistical report on the use of animals for scientific
purposes in Ireland. The HPRA is required to collect and make publicly available, on an annual
basis, statistical information on the use of animals in procedures, including information on the
actual severity of the procedures.
Authorisation and registration – Key 2017 figures:
Individual authorisations 319
Project authorisation 125
Individual amendments 74
Project amendments 186
Establishment renewals 22
481 518
323
271
319
72
128114 102
125
0
100
200
300
400
500
600
2013 2014 2015 2016 2017
Authorisations
Individuals
Projects
HPRA Annual Report 2017
35
SAFETY AND QUALITY
During 2017, there were 33 inspections completed, of which 18% were unannounced, to monitor
animal welfare standards and compliance with legislation. This total incorporated 25 establishment
authorisation inspections and eight compliance inspections.
One of the HPRA’s responsibilities in respect of scientific animal protection is to grant permission
to rehome animals if certain criteria are met that protect and provide for the animal’s overall well-
being. Early in 2017, we approved a pilot rehoming scheme for a group of dogs from Charles River
Laboratories as a result of the closure of a facility in County Mayo. Following the positive outcome
of the pilot, when a number of dogs were effectively rehomed through animal welfare
organisations, the rehoming scheme was subsequently extended. It was concluded after the
successful rehoming of 342 dogs and 249 cats confirming it as one of the largest projects of its
kind ever undertaken.
STAKEHOLDERS AND PARTNERS
In May, in co-operation with the Health Research Board and Science Foundation Ireland, we hosted
a 3Rs conference in Croke Park, Dublin. The conference presented over 200 delegates with
information and recommendations on how to apply the 3Rs to research with the aim of improving
animal welfare and achieving better science.
We published and disseminated three regulatory updates to provide stakeholders with the latest
news and guidance from the HPRA, with information on education and training, and with information
and best practices in respect of the 3Rs and compliance with the legislation.
In December, we delivered a Laboratory Animal Science and Training (LAST) lecture in relation to
the legislative and regulatory aspects of scientific animal protection.
HPRA Annual Report 2017
36
Controlled Drugs and Precursor Chemicals
AUTHORISATION AND REGISTRATION
Import, export and holding of controlled drugs (for legitimate purposes) are subject to licensing.
The Department of Health is the licensing authority while the HPRA handles the administrative
aspects of the application and licensing process. Licensing activity consists primarily of export and
import licences, and letters of no objection. Data for the past five years are outlined in the
accompanying graph.
The HPRA is the licensing authority for precursor chemicals. These are subject to different licensing
requirements, dependant on specific categories. The following table shows the licensing activity
since 2013.
Precursor Chemicals Licensing Activity 2013 2014 2015 2016 2017
Total 27 46 32 16 23
LEGISLATION AND REGULATION
Following commencement of the Misuse of Drugs (Amendment) Act 2016 on 4 May 2017,
changes were made to the requirements for controlled drug import and export licences. All
necessary adjustments to HPRA procedures and forms were subsequently implemented.
STAKEHOLDERS AND PARTNERS
Prior to the commencement of the new legislation, we communicated with relevant stakeholders
to remind them that a number of substances that were not previously controlled would now fall
under the scope of the Misuse of Drugs framework. We published the relevant details in the
HPRA’s Medicinal Products Newsletter in January and this was followed by the dissemination of an
e-mail update in April. Companies were advised to review products handled to ascertain any
impact of the proposed changes and to update procedures and authorisations where necessary.
2055 21302363 2343
2689
0
500
1000
1500
2000
2500
3000
2013 2014 2015 2016 2017
Controlled Drugs Licensing Activity
HPRA Annual Report 2017
37
Cosmetic Products The role of the HPRA is to regulate the manufacture, sale and supply of cosmetic products in Ireland.
We identify and address cosmetic product quality and safety issues, in conjunction with the HSE, so
that a cosmetic product will not compromise the health and safety of the consumer or the person
applying the product.
AUTHORISATION AND REGISTRATION
During 2017, we issued 174 cosmetics free sale certificates which may be required by companies
exporting products to third countries.
SAFETY AND QUALITY
As part of our proactive market surveillance activities, we conducted three inspections of cosmetic
distributors to assess compliance with the Cosmetics Regulation. Distributors were informed of any
non-compliances identified and requested to implement corrective actions.
Our reactive market surveillance includes investigation of quality-related complaints (compliance
cases), reports of adverse events relating to the use of cosmetics (vigilance cases) and serious risk
alerts received from other countries (RAPEX). In total, there was 312 reactive surveillance cases
initiated during 2017.
STAKEHOLDERS AND PARTNERS
We developed a cosmetic products information pack which was
published in March 2017 to guide stakeholders through placing a
cosmetic for sale on the market and to provide an easy-to-use
checklist to help ensure all regulatory requirements were met
before placing a cosmetic on the market. This initiative was
undertaken as a result of direct feedback from stakeholders in
2016.
We hosted three regulatory information seminars in Leitrim,
Limerick and Dublin during October to provide cosmetic
stakeholders with useful, up-to-date information on their
responsibilities under the Cosmetics Regulation. Given that many
attendees were small businesses, we invited a member of the
Local Enterprise Office to speak at each event also. These evening
events were well attended and the feedback from stakeholders
was that the information, which included printed copies of the
information pack, was relevant and well presented.
In addition, we launched a media information campaign in December to raise awareness among
consumers of the dangers presented by counterfeit cosmetics in the run up to the Christmas
period. The information was published by both print and online media and we participated in a
number of national and regional radio interviews. Consumers were informed on how to spot a
counterfeit cosmetic and of the risks these products can pose.
HPRA Annual Report 2017
38
Other Regulatory Programmes
INSPECTIONS, AUDITS AND MARKET COMPLIANCE
The Joint Audit Programme (JAP) is a key element of the quality system adopted by good
manufacturing practice (GMP) inspectorates in Europe and aims to ensure consistency of GMP
standards and a harmonised approach throughout Europe.
- A positive JAP evaluation of the HPRA was carried out from the 15 to 19 May by GMP
inspectors from Austria, France and Iceland, and an auditor from the Commission’s
Directorate General (DG) for Health and Food Safety. Our GMP inspections, manufacturers’
licensing, quality defects and recall programme, and sampling and analysis systems were
examined in addition to the legislation for both human and veterinary medicines and our
overarching quality management system. As part of the assessment, the conduct of a full GMP
inspection by the HPRA was observed by one member of the audit team.
- Also in 2017, the HPRA led two JAP evaluations of the GMP compliance programme of other
member states. One was at the State Institute for Drug Control (SIDC), the competent
authority for human medicines in the Slovak Republic, while the other was at the Agency for
Medicinal Products and Medical Devices of the Republic of Slovenia (JAZMP).
The successful completion and positive outcome of the HPRA’s JAP evaluation validates the
strength of our processes and procedures for inspection and quality defect management. Of
particular note, our audit was observed by the US FDA as part of its review of the equivalency of
HPRA systems in relation to the US/EU mutual recognition agreement (MRA) on GMP inspections.
A detailed data package was also prepared and presented to the FDA for its consideration as part
of competency assessment. The FDA subsequently confirmed that the HPRA has the capability,
capacity and procedures to carry out GMP inspections at an equivalent level. As a result, it is
anticipated that Ireland will be included on the list of recognised member states under the MRA
during 2018 and from that point forward the FDA can rely on HPRA inspections to replace its own
inspections.
Other EU contributions included leading on:
- the development of a new risk assessment tool for the selection of medicinal products and
active substances for surveillance testing;
- a new risk-based tool to support inspection and surveillance relating to heparin
manufacturers and their related products; and
- the development of a communication tool-kit for the Official Medicines Control Laboratory
(OMCL) Network.
We completed a pilot project, which commenced in 2016, on advertising compliance with regard
to advertising advisory boards. A report on the outcome of this project will be finalised in early
2018.
INNOVATION SUPPORT
Supporting innovation is one of the HPRA’s five strategic goals. This is in recognition of the pace of
development of new health products, technologies and platforms and the resulting potential to
provide huge benefits for patients. However, the changes being brought about by innovation can
also present challenges for the regulatory model as it is currently constructed. Our actions under
this theme during 2017 included the following:
HPRA Annual Report 2017
39
- This was the first full year of activity for the HPRA’s Innovation Office which provides
regulatory support and advice to individuals, academics, small and medium enterprises,
pharmaceutical and medical device companies, and other groups who are developing
innovative health products or technologies. A total of 38 of queries were received, mainly
from SMEs and academia, with the majority relating to medical devices, medicines and
borderline products.
- A new formal in-house horizon scanning process was developed during 2017 to enable the
HPRA to identify, at an early stage, developments and events that may require discussions at
an EU level and potential changes to the regulatory framework. There may also be a resulting
need to develop knowledge or expertise within the HPRA or to identify and recruit external
experts. The first report produced by the horizon scanning group focused on additive
manufacturing / 3D printing. A cross-organisational group is now moving ahead with the
implementation of the report recommendations. Linked to this initiative, the EU Innovation
Network adopted a HPRA proposal concerning a roadmap for the establishment of common
approach to horizon-scanning.
- The HPRA played a leading role in setting up an innovation project among members of the
International Coalition of Medicines Regulatory Authorities (ICMRA). Following an initial
survey, we prepared a project proposal that identified three work streams that will be the
focus of future activities. One of the work streams, focusing on outcomes of horizon scanning,
is jointly led by the HPRA and the EMA.
- The HPRA provides a classification service to stakeholders for products which are on the
borderline between medicines and medical devices and other categories such as cosmetics
and food supplements. This will generally determine the legislation under which a product be
regulated. During 2017, an integrated medicines and medical devices classification system for
handling requests from stakeholders was developed to optimise the consistency of HPRA
decision-making process. This will be implemented from Q1 2018.
HPRA Annual Report 2017
40
Outreach and Engagement
The HPRA is committed to a strategic focus on outreach and engagement with key partners and
stakeholders so as to enhance and maximise the effectiveness of the regulatory system.
In our outreach activities to support innovation developments in Ireland:
- The HPRA organised an innovation day in May in the O’Reilly Institute in UCD. Over 260
attendees registered for the event from various backgrounds including academia, research
networks, SMEs, other agencies with an interest in innovation and the pharmaceutical and
medical device industries. Feedback subsequent to the event was very positive with
stakeholders welcoming the HPRA’s desire to reach out and engage with innovators. Extensive
tweeting of @TheHPRA Twitter account during the day helped promote the HPRA to new
audiences.
- We participated in a number of external events to promote our supports to innovation
including the Medtech Innovation Showcase at the ‘Med in Ireland’ event organised by
Enterprise Ireland. This was attended by over 250 international companies, 70 indigenous
medtech companies and a number of other organisations focused on encouraging innovation
in Ireland. We also exhibited and presented at the ‘Taking Care of Business’ event organised
by the Department of Business, Enterprise and Innovation in November. In the same month,
the HPRA’s innovation office exhibited at the SME Information day held at the EMA.
- As part of outreach activities, we met with a variety of research bodies including the RCSI, the
Regenerative Medicine Institute (REMEDI) and the Centre for Cell Manufacturing Ireland
(CCMI). We also met with Science Foundation Ireland (SFI) and the National Institute for
Bioprocessing, Research and Training (NIBRT) to discuss HPRA supports for innovation and
areas of common interest
- The HPRA is an active participant of the Pharmaceutical Education and Research with
Regulatory Links (PEARRL) programme. As part of this initiative, four early stage researchers
were given the opportunity to work within the medicines assessment area for three months so
that they could get an understanding of the regulatory process. As part our participation in
this programme, we were involved in organisation of a regulatory science symposium in Cork
in June 2017 entitled ‘Regulatory Support of Innovation in the Pharmaceutical Industry’.
- Staff also presented on horizon-scanning and innovation supports to the National Centre for
Pharmacoeconomics and industry association meetings.
- Additionally, we commenced a review of the HPRA’s contribution to external education
programmes which incorporates consideration of the most appropriate formats for future
activities. We met with APPEL (Affiliation for Pharmacy Practice Experiential Learning) to
discuss involvement in education of pharmacists.
Stakeholder communications and engagement:
- The HPRA was pleased to participate as one of a number of education partners working with
the Irish Platform for Patient Organisations, Science & Industry (IPPOSI) to deliver a Patient
Education Programme in the area of health innovation. The programme, which was specifically
tailored for Irish patient communities, was piloted from September 2017 to March 2018 based
on a ‘blended learning’ approach consisting of e-learning and face-to-face sessions. The
HPRA module, which ran for five weeks during November and December, was focused on
regulatory affairs, medicines safety and pharmacovigilance. The programme students
completed three modules in total with the additional modules focused on clinical trials and
health technology assessments.
- The HPRA's first ever national information campaign was launched in September 2016. The
campaign, which incorporates radio, digital and print advertising, was repeated in 2017 during
March / April and again in October. The focus of the HPRA adverts is to highlight the
importance of the safe use of medicines as well as medication adherence in general. Our key
HPRA Annual Report 2017
41
message to members of the public is to take care when taking medication and specifically to
be aware of and read the information and directions for use that come with every medicine.
- Throughout the year, we continued our media communications programme to proactively
communicate important safety messages and to build awareness of the role of the HPRA. We
issued 25 press releases and website statements concerning safety and regulatory issues to
ensure consumers, healthcare professionals and other stakeholders received timely and
accurate information and advice. In a number of instances, these communications resulted in
national and regional media interviews with a HPRA spokesperson. In addition, we responded
to more than 500 initial and follow-up queries from national, local and specialist media during
the year.
- The HPRA website – www.hpra.ie – is a key communications channel and we continuously
monitor and analyse key visitor and usage statistics. Among the key findings from 2017 were:
o Almost 314,000 unique visitors accessed our website during the past twelve months
representing a more than 10% increase compared to 2016.
o There were in excess of 770,623 visits in total throughout the year.
o Of those who accessed the site, close to 20% were new or first time users.
- The @TheHPRA Twitter account was launched in late 2016 as a tool to support our
communications activities and direct additional traffic to the HPRA website. We continued to
develop our Twitter activity during 2017 and by year end we had secured more than 800
followers. Among the highlights was our participation in an EU-wide social media campaign to
promote the reporting of suspected side effects from medicines. This campaign was
supported by a range of patient organisations and other national health agencies.
HPRA information seminars and training events provide regulatory guidance and updates to a
range of stakeholders. The HPRA also partners with other regulatory organisations to co-host
relevant sessions. During 2017, we hosted the following events:
- VISTART Workshops, 1 – 2 February and 30 – 31 March
- GMP Information Day, 7 February
- GDP Information Day, 8 February
- JAMS Workshops, 10 – 11 April and 30 November
- 3Rs Information Day, 17 May
- Innovation Day, 25 May
- Brexit Stakeholder Meeting, 31 August
- Cosmetic Information Days: 11 October in Carrick-on-Shannon, 12 October in Dublin and 19
October in Limerick
- Biosimilar Information Seminar, 18 October
- PICs Training, 23 – 27 October (Nibrt)
- Working Group of Quality Managers and Working Group of Communications Professionals, 27
– 29 November
- EMA QWP Assessor Training, 4 – 5 December
At European and international
- We continued providing technical assistance to the Zambia Medicines Regulatory Authority
with our consortium partners, and issued a ‘Health Systems Strengthening Programme for
Zambia’ report in June.
- In early 2017, the World Health Organisation (WHO) announced Ireland as the location for the
next International Conference of Drug Regulatory Authorities (ICDRA) which takes place in
September 2018. This WHO global event provides regulatory authorities with a unique forum
to meet and discuss ways to strengthen global collaboration in the area of medicines’
regulation. Throughout the year, the HPRA progressed planning and preparation for the five-
day conference which is expected to attract more than 300 delegates from up to 100
countries worldwide. This included a meeting in Dublin with WHO representatives where a
HPRA Annual Report 2017
42
range of items were reviewed and agreed in addition to a site visit to the meeting venue. The
development of a dedicated conference website – icdra2018.ie – was also completed and
commenced taking registrations in early 2018.
- The UK withdrawal from the EU has potentially significant implications for the European health
products sector and regulatory network as a whole and particularly for Ireland with its shared
market place. Protecting the availability of medicines for Irish patients and the integrity of our
market are key strategic aims of the HPRA’s Brexit-related activities while also optimising our
role within the European regulatory network and maintaining our strong working relationships
with UK colleagues. There were a number of Brexit-related initiatives either completed or
progressed in 2017 including:
o A strategic review by the senior management of the implications of Brexit and the
resulting HPRA response. A detailed, dedicated plan was agreed focusing on five key
areas: communication, existing work, new work, stakeholder influence and resourcing.
As part of the initial rollout of the plan, an internal working group was established
with representatives from across each of the products areas regulated by the HPRA.
o In August, we held a successful stakeholder event which was attended by almost 300
delegates from the biopharma, medtech and life sciences sector. The meeting was
one of the first opportunities for stakeholders from across the sector to meet and
engage in respect of the challenges being presented by Brexit. The HPRA intends to
host further such meeting during the second half of 2018 once greater clarity on the
conditions and terms of the UK exit is available.
o The HPRA working group developed a detailed guidance document for industry
stakeholders to complement similar information published at a European level. The
guide was published in a newly established dedicated Brexit section on the HPRA
website in December.
o We participated in a number of speaking engagements to outline the potential
impact on the Irish market and the planned HPRA Brexit strategy.
o At a European level, we continue to be very active participants in initiatives and
preparations linked to Brexit. This includes our high-level contribution to EMA
activities and our membership of the HMA Brexit Task Force.
Key outreach and engagement figures 2017
Public consultations we held
- Regulatory fees
- Consultation on medical devices distributor guidance
2
Public consultations we responded to:
- Included CORU, Department of Health, European Commission;
Heads of Medicines Agency, HSE, Medical Council and PSI
12
Events managed by HPRA events teams 16
Freedom of information requests 20
Requests received in accordance with the Data Protection Acts 2
Parliamentary questions 93
Queries from government departments or members of the Oireachtas 76
Protected disclosures received by external persons under section 7(2)
of the protected Disclosures Act, of which investigation is:
- Concluded
- Ongoing
7
1
Protected disclosures from HPRA staff members 0
Complaints 0
Customer service queries 3096
HPRA Annual Report 2017
43
Organisation Development
The HPRA is committed to having the necessary corporate functions, systems and supports in place to
deliver on our public health mission. We must ensure that our organisational capabilities continue to
expand and evolve in line with regulatory and scientific developments and that we adapt to other
changes in our operating environment.
The BEMA (Benchmarking of European Medicines Agencies) assessment of the HPRA’s
management systems and systems for regulating human and veterinary medicines took place on
10 to 13 October, by an assessment team from three other EU countries. The assessment against a
range of indicators was thorough and challenging, with very positive results for the HPRA,
including ‘best practices’ acknowledged in a number of areas. A small number of improvement
actions will be addressed in 2018.
During 2017, the HPRA’s quality management system continued to be extended with the
deployment of policies and procedures in preparation for the upcoming General Data Protection
Regulation, new policies on risk management, energy and the internal audit strategy, and new
procedures to better support innovation office queries and media queries. Guidance documents
for stakeholders were published on the website including a guide to the notified body designation
process, and a guide to scientific and regulatory advice for GXP activities.
We continued our preparations for compliance with the General Data Protection Regulation
(GDPR) which comes into force on 25 May 2018. This included the establishment of a data
processing register.
Management and development of our staff is
critical to the success of the HPRA’s regulatory
functions. Using a framework of six core
themes, our HR and Change Strategy 2016 –
2020 identifies and delivers key supports
required by the organisation to achieve its
goals over the coming years.
During the year:
- We established a programme to further develop
managerial capability in the HPRA and delivered
three of the six modules of the management
development programme to all managers in the
organisation.
- A strategic approach to succession planning was
developed and a key role review and forecasting analysis completed. Development plans were
agreed and are underway. In addition, we began work on developing a scientific role skills
matrix and approach agreed for the key role review.
- A new graduate recruitment programme was launched, with an 18-month programme for two
rotations to be offered to candidates in relevant scientific disciplines. By year-end, interviews
were completed and candidates identified to commence their placements in September 2018.
- We continued to deliver existing programme of activities, such as health and wellness
programmes, organisational awareness fora and lunchtime learning. The receipt of a gold
Active@work award from the Irish Heart Foundation was recognition of our efforts in this
regard.
- Our LinkedIn presence was established with online recruitment testing in progress.
HPRA Annual Report 2017
44
In consideration of the changing regulatory environment for medical devices, we reviewed the
internal structures for the delivery of expanded functions with the management committee and
held a number of workshops for staff. The subsequent report presented to the Authority identified
the need for changes to the structure to allow us to effectively plan and implement the new EU
Regulations. These involve bringing together in one department all medical devices staff except for
the auditors who remain with the inspectorate section. Plans were underway by the end of the year
to begin this process and recruit a head for the new department.
IT developments
- EOLAS is the HPRA’s new workflow technology solution, which will provide the organisation
with a single workflow and data management system to support its regulatory activities. It will
also incorporate new EU standards for regulatory data management. In 2017, the system was
deployed to our Veterinary Sciences department in addition to the receipts and validations,
and quality management sections. End users were supported through the provision of both
general and role specific training and this was supplemented with training documents and
online videos. Following go-live, end users worked closely with the project team to identify
and manage any issues or adjustments required. This user insight supported ongoing
preparations for deployment in 2018 to human medicines procedures.
- There were 417,211 regulatory submissions made through the Common Electronic Submission
Portal (CESP), which is managed by the HPRA on behalf of the wider EU regulatory
community. By year-end, there were 5,000 organisations availing of CESP with over 12,000
individual users.
- The HPRA participated, as part of a European consortium, in the European Commission’s
Horizon 2020 research programme on the openMedicine project that provided
recommendations on the identification of medicines in a cross border setting, this project
concluded in 2017.
Finance
- The 2017 financial statements presented in this report were prepared and submitted for audit
to the Comptroller and Auditor General. All financial transactions during the period under
review are reflected and reported upon in these statements as is our commitment to the
highest standards of corporate governance.
- The annual review of regulatory fees for 2018 was completed following public consultation
and resulted in the introduction of a modest general fee increase. Fees had not been
increased by the HPRA since 2010 with reduced fees introduced both in 2011 and 2012.
- Invoicing was introduced to support the introduction of a fee based funding model for the
HPRA’s regulatory functions in respect of medical devices. The finance team engaged with
relevant stakeholders as necessary in respect of the fees issued and payments received while
monitoring the collectability rate on an ongoing basis.
The HPRA, as a public sector body, is required to report annually on its energy usage and actions
taken to reduce consumption in accordance with the European Union (Energy Efficiency)
Regulations 2014 (S.I. No. 426 of 2014). As an organisation, we use electricity for lighting, air
conditioning or heating as required and the provision of hot water; natural gas is used for central
heating. In 2017, the HPRA consumed 804.5 MWh* of energy consisting of:
- 600.5 MWh of electricity
- 203.9 MWh of fossil fuels
- 0 MWh of renewable fuels.
*these figures may differ from those officially published by the SEAI – official figures were not available at
time of printing.
HPRA Annual Report 2017
45
Authority and Committees
The Authority of the HPRA met six times in 2017 and considered a number of strategic matters
including corporate policy, planning and financial matters. The latter included monthly
management accounts, annual budgets and the financial statements for 2016. The Authority also
reviewed update reports from the Statutory Advisory Committees and the Audit and Risk
Committee. In addition, it reviewed the licences for all medicinal healthcare products as approved
by the Management Committee.
The number of meetings attended by each Authority member during 2017 was as follows:
Authority Member
Number of meetings
held during the
period the member
was on the Authority
Number of meetings
attended during the
period the member
was on the Authority
Ms. Ann Horan (Chairperson) 6 5
Mr. Pat Brangan 6 6
Mr. Wilf Higgins 6 6
Mr. David Holohan 6 6
Prof. Mary Horgan 6 2
Mr. Brian Jones 6 6
Prof. Elizabeth Keane 6 6*
Prof. Caitriona O’Driscoll 6 6
Dr. Diarmuid Quinlan 6 5*
*One via T/C
- The Audit and Risk Committee, a subcommittee to the Authority, met four times in 2017.
Further details are provided in the HPRA’s Financial Statements.
- The Advisory Committee for Human Medicines met on one occasion in 2017. The Clinical
Trials Sub-Committee is a sub-committee to the Advisory Committee for Human Medicines
and it met twelve times in the past year.
- The Advisory Committee for Veterinary Medicines met twice as did the Advisory Committee
for Medical Devices.
- The National Committee for the Protection of Animals Used for Scientific Purposes, a statutory
committee to provide guidance to the regulator and those working in this area, met twice in
2017.
Decisions of the Authority:
The terms of reference of the Authority, which are published on the HPRA website, include an
overview of how the Authority operates, an overview of all decisions taken by the Authority and those
devolved to the Management Committee.
HPRA Annual Report 2017
46
The following decisions are reserved functions of the Authority:
- The Authority takes decisions relating to very significant and serious public and/or animal
health matters except in circumstances where a meeting of the Authority cannot be
convened, in which case the Management Committee takes the decision and informs the
Chairperson at the earliest opportunity and the Authority as soon as is practical.
- The Authority refuses applications, or suspends, revokes or terminates authorisations as
set out in legislation except in circumstances where:
(a) the urgency is such that a meeting of the Authority cannot be convened, or
(b) the application or authorisation is subject to a binding European decision, or
(c) the application or authorisation is for a clinical trial or clinical investigation; in which
case the Management Committee takes the decision and informs the Authority.
- Through its Audit Committee, the Authority approves the internal financial controls and
the financial audit function and satisfies itself that the financial controls and systems of
risk management are robust and defensible. The Authority appoints the internal financial
auditor.
- The Authority approves the investment policy, major investments, capital projects and the
terms of major contracts.
- Significant acquisitions and the disposal or retirement of assets above a threshold set by
the Authority are subject to Authority approval.
- The Authority approves treasury policy and risk management policies.
- The Authority approves corporate plans as required.
- The Authority approves the annual budget, monitors expenditure and supervises the
preparation and submission of the annual statutory accounts.
- The Authority makes an annual report on the activities of the HPRA, including a financial
statement, to the Minister for Health. This report is then published.
- The Authority selects and appoints the Chief Executive, with the consent of the Minister
for Health. The terms of office and the remuneration of the Chief Executive are
determined by the Minister for Health, after consultation with the Authority and with the
consent of the Minister for Finance. The Authority, through its Performance Review
Committee, conducts a process of annual performance appraisal of the Chief Executive.
Succession planning for the role of Chief Executive is also undertaken by the Authority.
HPRA Annual Report 2017
47
Appendix 1 – Committee Members
MANAGEMENT COMMITTEE
Dr Lorraine Nolan
Chief Executive
Ms. Rita Purcell
Deputy Chief Executive
Dr Gabriel Beechinor
Director of Veterinary Sciences
Dr Jayne Crowe
Director of Human Products Authorisation and Registration
Dr Caitríona Fisher
Director of Quality, Scientific Affairs and Communications
Dr Joan Gilvarry
Director of Human Products Monitoring
Mr Kevin Horan
Director of Information Technology and Business Services
Mr John Lynch
Director of Compliance
M. Lynsey Perdisatt
Director Human Resources and Change
AUTHORITY (BOARD)
Ms Ann Horan – Chairperson
Dr Patrick Brangan
Mr Wilfrid Higgins
Prof Mary Horgan
Mr David Holohan
Mr Brian Jones
Prof Elizabeth Keane
Prof Caitriona O’Driscoll
Dr Diarmuid Quinlan
AUDIT COMMITTEE
Dr Patrick Brangan – Chair
Mr David Holohan
Prof Elizabeth Keane
HPRA Annual Report 2017
48
ADVISORY COMMITTEE FOR HUMAN MEDICINES
Prof Mary Horgan – Chair
Dr Kevin Connolly
Prof Desmond Corrigan
Ms Maria Egan
Prof Tom Fahey
Prof David Kerins
Ms Fionnuala King
Prof Patrick Murray
Dr Fionnuala Ní Ainle
Dr Brian O’Connell
Mr Ronan Quirke
Dr Patrick Sullivan
ADVISORY COMMITTEE FOR VETERINARY MEDICINES
Dr Patrick Brangan – Chair
Dr Ruadhrí Breathnach
Ms Eugenie Canavan
Dr Martin Danaher
Dr Helena Kelly
Dr Nola Leonard
Dr Bryan Markey
Dr Ciaran Mellett
Dr Warren Schofield
Dr Robert Shiel
Dr Christina Tlustos
ADVISORY COMMITTEE FOR MEDICAL DEVICES
Mr Wilfrid Higgins – Chair
Prof David Barton
Dr Vivion Crowley
Mr Ger Flynn
Dr Fergal McCaffrey
Ms Margaret O’Donnell
Prof Martin O’Donnell
Prof Richard Reilly
Prof Mary Sharp
Mr Sean-Paul Teeling
Prof Sean Tierney
HPRA Annual Report 2017
49
CLINICAL TRIALS SUB-COMMITTEE OF THE ADVISORY COMMITTEE FOR HUMAN MEDICINES
Dr Patrick Sullivan – Chair
Dr Liam Bannan
Dr Geraldine Boylan
Dr Paul Browne
Dr Peter Crean
Prof Lee Helman (CT Expert)
Dr Filip Janku (CT Expert)
Dr Catherine Kelly
Dr Patrick Morris
Dr Thomas Peirce
Dr Bryan Whelan
Dr Jennifer Westrup
EXPERTS SUB-COMMITTEE OF THE ADVISORY COMMITTEE FOR HUMAN MEDICINES
Prof Mary Horgan – Chair
Dr Linda Coate
Dr Kevin Connolly
Mr James Colville
Dr Noreen Dowd
Dr Stephen Eustace
Prof Stephen Flint
Dr Tim Fulcher
Dr Joseph Galvin
Dr Patrick Gavin
Dr Paul Gallagher
Dr Kevin Kelleher
Dr Catherine Kelly
Dr Mary Keogan
Prof David Kerins
Dr Mark Ledwidge
Dr Frank Murray
Dr Yvonne O’Meara
Dr Cormac Owens
Dr Jogin Thakore
Dr Gerry Wilson
ADVISORY SUB-COMMITTEE FOR HERBAL MEDICINES
Prof Des Corrigan – Chair
Dr James Barlow
Dr Kevin Connolly
Mrs Ingrid Hook
Ms Claudine Hughes
Ms Anna-Maria Keaveney
Dr Celine Leonard
Dr Donal O’Mathuna
Dr Camillus Power
Dr Helen Sheridan
Dr Emma Wallace
HPRA Annual Report 2017
50
Appendix 2 – Presentations 2017
THIRD LEVEL PRESENTATIONS
Institution Course Presentation Title
Athlone IT Veterinary Nursing Regulation of Veterinary Medicines
DIT Medical Device
Decontamination (CPD)
Medical Devices Legislation / Medical Devices
Vigilance
EU Network
Training Centre
Training Champions
Workshop
Scientific and Regulatory Training for Veterinary
Medicines
IT Sligo
Medical Biotechnology
and Pharmaceutical
Science
GMP, Quality Defects, Biological Medicines and
Pharmacovigilance (Case Study based
Workshop)
Letterkenny IT Veterinary Nursing Regulation of Veterinary Medicines
NUIG / IT Sligo Medical Technology
Regulatory Affairs Medical Devices Legislation
RCSI Nurse/Midwife
Prescribing The Role of the HPRA and Pharmacovigilance
RCSI Pharmacy Quality Defect in Medicines
RCSI Pharmacy Regulation of Similar Biological Medicines
RCSI Pharmacy Regulation of Biotechnology Therapeutics
RCSI Pharmacy Regulation of Generic and Interchangeable
Medicines
RCSI Pharmacy Regulatory Affairs and Regulatory Authorities
RCSI Pharmacy Regulation of Medicine
St. Johns, Cork Veterinary Nursing Regulation of Veterinary Medicines
TCD Hospital Pharmacy Authorisation of Medicines
TCD Immunology Regulation of Medicines / Regulation of
Biological Medicines
TCD Pharmaceutical
Medicine Risk Management Plans: An Overview
TCD Pharmaceutical
Medicine Pharmacovigilance, Where are we Now?
TCD Pharmaceutical
Medicine
Communication of Drug Safety Data
TCD Pharmaceutical
Medicine The Role of CMDh
HPRA Annual Report 2017
51
TCD Pharmaceutical
Medicine
Overview of the Pharmacovigilance Risk
Assessment Committee
TCD Pharmaceutical
Medicine Regulation of Biologicals
TCD Pharmaceutical
Medicine GCP Inspections
TCD Pharmaceutical
Medicine
Legal provisions Governing the SmPC, Package
Leaflet and Labelling
TCD Pharmaceutical
Medicine Traditional Herbal Medicinal Products (THMPs)
TCD Pharmaceutical
Medicine Quality Standards and Pharmacopoeias
TCD Pharmaceutical
Medicine Falsified Medicines Directive
TCD Pharmaceutical Sciences Regulation of Biologicals
TCD Pharmacy Overview of Pharmacovigilance
TCD Pharmacy Authorisation of Medicines and the Role of the
HPRA
TCD Pharmacy Quality Defect in Medicines
TCD Regulatory Affairs
Workshop Medical Devices Legislation
TCD Science The Role of the Regulatory Pharmacist
UCC
Laboratory Animal
Science and Training
(LAST)
Legislative and Regulatory Aspects of Scientific
Animal Protection
UCC PEARLL – Regulatory
Support of Innovation Innovation Benefits and Risks
UCC PEARLL – Regulatory
Support of Innovation
Process Analytical Technology and Continuous
Manufacturing
UCC Pharmacy Investigating and Reporting Quality Defects in
Medicines
UCC Pharmacy Regulation of Biological and Biosimilar
Medicines
UCD Bioengineering Medical Devices Legislation
UCD Clinical and Translational
Medicine Medical Devices Regulation and Innovation
UCD Nurse/Midwife
Prescribing The Role of the HPRA and Pharmacovigilance
UCD Regulatory Affairs and
Toxicology Medical Devices Legislation
UCD Regulatory Affairs and
Toxicology Pharmaceutical Regulatory Affairs
HPRA Annual Report 2017
52
UCD Veterinary Medicine Regulation of Veterinary Medicines
University of
Copenhagen
Regulatory Affairs -
Biopharmaceuticals
Biosimilars: Quality, Non-clinical and Clinical
Requirements
REGULATORY PRESENTATIONS
Event/Organiser Presentation Title
AFI (European Clinical Trial Day) The Future of Clinical Research
Association of the European Self-
Medication Industry
Reclassification of Medicinal Products in the Irish
Regulatory Setting
BEAI Annual Conference Medical Device Innovation and Regulation
Beyond Compliance Meeting Medical Device Registries
BioProduction Congress Practical Advice on GMP Inspections
CASSS A Holistic Regulatory Approach to Accelerated CMC
Development
Cattle Association of Veterinary
Ireland Medicines Regulation - European Legislation Update
Chinese FDA New European Regulations on Medical Devices –
Perspective of the HPRA
Curam MedTech Minds Medical Device Regulation
DIA Benefit Risk Strategies
Workshop Referrals – Experience gained and Emerging Trends
DIA Conference Medical Device Regulation
DIA EuroMeeting 2017 SCOPE - Communicating Safety Information to Health
Care Professionals in Europe
EDQM How to Build a Good CEP Application - ICH Q3D
EMA Stakeholder Day Future Opportunities for Pharmacovigilance
EU Medical Device Clinical
Research Conference Medical Device Regulation
European Alliance for
Personalised Medicine Growth in Personalised Healthcare
GS1 Ireland Healthcare User
Group (HUG) Regulatory Update on Medical Devices
HISI Annual Conference Introduction to UDI in the MDR/IVDR
HISI Annual Conference Regulation of Medical Device Standalone Software
HSE (Registered Nurse
Prescribers) The HPRA’s Exempt Medicinal Products Programme
HPRA Annual Report 2017
53
Irish Medtech Association Regulation of Medical Devices – Increasing Patient Safety
and Promoting Timely Innovation
Irish Medtech Association Sterility Assurance: Regulatory Expectations and
Common Deficiencies
Klifovet, Munich Veterinary Medicines: A Review and Look into the Future
of a National Competent Authority
MedTec Europe MEDDEV 2.7/1 Revision
MedTec Ireland Introduction to the new MDR
MedTec Ireland Medical Technology Sector in Ireland
National HPV Vaccine Conference Pharmacovigilance and HPV Vaccine
NUIG / HPRA Innovation
Workshop Regulatory Pathway for Medical Devices in Europe
NUIG / HPRA Innovation
Workshop HPRA Approach to CI Assessment under MDD
NSAI Notified Body Designation process
Official Medicines Control
Laboratory Network
Risk Assessment in Market Surveillance Testing
Programmes
Parenteral Drug Association,
Ireland
Exploring the Concept of Formality and Informality in
Quality Risk Management
PCR Innovators Day Medical Device Regulation
PDA Quality Risk Management
Workshop
Improvement Initiatives in relation to Quality Risk
Management
Pharmaceutical Inspection Co-
operation Scheme Validation Activities and Regulatory Expectations
Pharmig Annual Conference Contamination Control Strategy
PMDA, Japan Risk-based GMP Inspection Planning
QP Forum GMP Updates
Taking Care of Business
(Department of Business,
Enterprise and Innovation)
The Role of the HPRA and Our Support of Innovation
TÜV SÜD TAVI Valves
World Self-Medication Industry
Regulators Forum Innovation in Medicines Reclassification
HPRA Annual Report 2017
54
Appendix 3 – Publications and Articles 2017
DRUG SAFETY NEWSLETTERS
Edition Articles
March
79th Edition
Fluconazole – reminder not to use in pregnancy
SGLT2 inhibitors and risk of lower limb amputation (mainly toe)
Reports of keratoacanthoma with ingenol mebutate
Adverse reaction reporting – reminder
Direct Healthcare Professional Communications published on the HPRA
website since the last Drug Safety Newsletter
April
80th Edition
Valproate-containing medicines – new EU review initiated
July
81st Edition
Valproate (Epilim) and Developmental Disorders: Update on ongoing EU
review
Domperidone-containing medicines: reminder of the risk of cardiac
adverse reactions-restricted indication, contraindications and reduced
dose and duration of use
New CPD e-learning module on reporting suspected adverse drug
reactions
August
82nd Edition
Daclizumab (Zinbryta) and risk of severe liver injury: initiation in multiple
sclerosis now restricted, promptly review patients already on treatment
Gabapentin – respiratory depression without concomitant opioid use
Amoxicillin; co-amoxiclav – very rare reports of DRESS (drug reaction
with eosinophilia and systemic symptoms)
November
83rd Edition
Quinine – reminder of safety profile and potential drug-drug
interactions particularly where used for nocturnal leg cramps
Flucloxacillin and concomitant paracetamol – risk of high anion
gap metabolic acidosis in very rare cases
Epoetins: new warnings on Severe Cutaneous Adverse Reactions
(SCARs)
Adverse reaction reporting during 2016
December
84th Edition
Conclusion of European Review of Gadolinium Contrast Agents –
Publication of European Commission Decision
December
85th Edition
Daclizumab (Zinbryta) and risk of severe liver injury – EU wide review
concludes and confirms further restrictions to reduce riskof liver
damage
New contraindication for injectable methylprednisoloneproducts
containing lactose (Solu-Medrone 40 mg / vial) in patients with cows’
milk allergy
Warning about the use of Xofigo (radium-223 dichloride) in
combination with Zytiga (abiraterone acetate) and prednisone or
prednisolone: ongoing clinical trial shows an increased risk of death and
fractures
HPRA Annual Report 2017
55
HUMAN MEDICINES ARTICLES – EXTERNAL PUBLICATIONS
Month Publication Topic
January MIMS Otezla (apremilast) – Important advice regarding
suicidal ideation and behaviour
February IMF Miconazole and Warfarin – Reminder of the potential
for Interaction
MIMS Levetiracetam 100mg/ml Oral Solution- Global
reports of medication errors resulting in the
administration of higher than intended doses of
levetiracetam
March
MIMS Lenalidomide (Revlimid) – Advice regarding viral
reactivation
MIMS Respiratory
Supplement
Improved access to educational materials on the
HPRA website
MIMS Cardiovascular
Supplement
Miconazole and warfarin - Reminder of the potential
for interaction
April MIMS SGLT2 inhibitors and risk of lower limb amputation
(mainly toe)
May
MIMS Valproate-containing medicines – new EU review
initiated (main edition)
MIMS Oncology
Supplement
Reports of keratoacanthoma with ingenol mebutate
June
MIMS Fluconazole – reminder not to use in pregnancy
MIMS Respiratory
Supplement
Advice on potential interaction between cobicistat-
containing products and corticosteroids primarily
metabolised by CYP3A: risk of adrenal suppression
July/August
MIMS Domperidone-containing medicines: Reminder of
the risk of cardiac adverse reactions restricted
indication, contraindications and reduced dose and
duration of use
MIMS Diabetes
Supplement
SGLT2 inhibitors and risk of lower limb amputation
(mainly toe)
August IMF Domperidone-containing medicines: Reminder of the
risk of cardiac adverse reactions-restricted indication,
contraindications and reduced dose and duration of
use
September
MIMS Amoxicillin; co-amoxiclav – very rare reports of
DRESS (drug reaction with eosinophilia and systemic
symptoms)
MIMS Pain
Supplement
Gabapentin – respiratory depression without
concomitant opioid use
October MIMS Daclizumab (Zinbryta) and Risk of Severe Liver Injury:
Initiation in Multiple
Sclerosis Now Restricted, Promptly Review Patients
Already on Treatment
MIMS Women’s Health
Supplement
Reminder that Fluconazole Should Not be Used in
Pregnancy
HPRA Annual Report 2017
56
November
MIMS Epoetins: New Warnings on Severe Cutaneous
Adverse Reactions (SCARs)
MIMS Diabetes
Supplement
High-Strength Insulin Preparations
December
MIMS New CPD e-learning module on reporting suspected
adverse drug reactions
MIMS Compendium Domperidone-containing medicines: Reminder of the
risk of cardiac adverse reactions restricted indication,
contraindications and reduced dose and duration of
use
HUMAN MEDICINES – PEER REVIEWED AND CONFERENCE PAPERS (HPRA CONTRIBUTORS)
Title Authors Publication / Event
Assessing awareness and attitudes
of healthcare professionals on the
use of biosimilar medicines: A
survey of physicians and
pharmacists in Ireland
O'Callaghan, J., Bermingham,
M., Leonard, M., Hallinan, F.,
Morris, J.M., Moore, U. and
Griffin, B.T.
Journal of Regulatory
Toxicology and
Pharmacology, 88, 252-
261
Knowledge of adverse drug
reaction reporting and the
pharmacovigilance of biological
medicines: A survey of healthcare
professionals in Ireland
O'Callaghan, J., Griffin B.T.,
Morris, J.M., and
Bermingham, M.
BioDrugs Journal
(accepted for
publication)
Assessing awareness and attitudes
of healthcare professionals on the
use of biosimilar medicines: A
survey of physicians and
pharmacists in Ireland
O'Callaghan, J., Bermingham,
M., Leonard, M., Hallinan, F.,
Morris, J. M., Moore, U. and
Griffin, B. T.
Presentation, Irish
Nephrology Society
Annual Scientific
Meeting, Dublin, March
2017
Assessing awareness and attitudes
of healthcare professionals on the
use of biosimilar medicines: A
survey of physicians and
pharmacists in Ireland’
O'Callaghan, J., Bermingham,
M., Leonard, M., Hallinan, F.,
Morris, J. M., Moore, U. and
Griffin, B. T.
Poster, All Ireland
Schools of Pharmacy
Conference, Cork, April
2017
VETERINARY MEDICINES ARTICLES – EXTERNAL PUBLICATIONS
Publication Topic
Veterinary Ireland Journal The regulation of the scientific and educational use of large
animals
Veterinary Ireland Journal Availability of veterinary medicinal products in Ireland
Veterinary Ireland Journal Antimicrobial resistance – update on European developments to
control it
It’s Your Field Care in use and disposal of sheep dips
It’s Your Field Exceptional authorisation of veterinary medicines
It’s Your Field Pharmacovigilance inspections
HPRA Annual Report 2017
57
NEW INDUSTRY GUIDANCE DOCUMENTS
Document Title Month
Submission of Mock-Ups for Variations to Veterinary Products January
Placing Medical Device Standalone Software on the Market June
Scientific and Regulatory Advice for GXP activities October
Electronic Submissions – Medical Devices November
Notified Bodies – Designation Process November
Clinical Trials Regulation (EU) No. 536/2014 Pilot Project - Ireland December
Brexit Guidance - Human and Veterinary Medicines December